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The presence of a common legal theory does not establish typicality when proof of a violation requires individualized inquiry.' Elizabeth M. v. Montenez, 458 F.3d 779, 787 (8th Cir. 2006) (citing Parke v. First Reliance Stnd. Life Ins. Co., 368 F.3d 999, 1004-05 (8th Cir. 2004)). '[I]n situations where claims turn on individual facts, no economy is achieved, and the typicality requirement cannot be met.' Mahoney, 204 F.R.D. at 154 (citing Guillory v. American Tobacco Co., No. 97 C 8641, 2001 U.S. Dist. LEXIS 3353, 2001 WL 290603, at *5 (N.D. Ill. Mar. 20, 2001)) (finding typicality requirement not satisfied where claims inconsistent from one plaintiff to another).
