---
title: "Draft the class-action complaint from the facts-and-issues brief"
url: "https://ailawframework.com/practice/class-actions-representative-proceedings/draft-the-representative-pleading-from-the-facts-and-issues-brief/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A7-T1-R10-US"
practice_area: "Class Actions / Representative Proceedings"
tier: "red"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Draft the class-action complaint from the facts-and-issues brief

> List the facts in the brief against each Rule 23(a) prerequisite and against the Rule 23(b) type the lawyer has selected. Write no paragraph of the complaint.

Canonical page: https://ailawframework.com/practice/class-actions-representative-proceedings/draft-the-representative-pleading-from-the-facts-and-issues-brief/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Class Actions / Representative Proceedings](https://ailawframework.com/practice/class-actions-representative-proceedings.md) |
| Human involvement | Red: Lawyer writes; AI may check, clarify or collect data |
| How AI is used | List the facts in the brief against each Rule 23(a) prerequisite and against the Rule 23(b) type the lawyer has selected. Write no paragraph of the complaint. |
| What the lawyer must review | You write the complaint. By presenting it you certify, under Rule 11(b), that the claims and legal contentions are warranted by existing law or a nonfrivolous argument, and that the factual contentions have evidentiary support, after an inquiry reasonable in the circumstances. Rule 23(a) and the chosen branch of Rule 23(b) are the certification theory. Formal Opinion 512: you verify generated authorities before they are filed. Open any standing order on generative AI for the assigned judge. |
| Written for | United States |
| Applies to | [Draft the representative pleading from the facts-and-issues brief](https://ailawframework.com/practice/class-actions-representative-proceedings/draft-the-representative-pleading-from-the-facts-and-issues-brief.md) |

## Checking plan

- What the AI does: List the facts in the brief against each Rule 23(a) prerequisite and against the Rule 23(b) type the lawyer has selected. Write no paragraph of the complaint.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- A securities class action may also have to meet the Private Securities Litigation Reform Act. Open that statute if the claim is under the securities laws.
- Do not file an Australian representative pleading, or a group-member definition from Part IVA, in a federal district court.

## Sources

- [Federal Rule of Civil Procedure 23(a) and 23(b)](https://www.law.cornell.edu/rules/frcp/rule_23) (checked 2026-10-22)
- [Federal Rule of Civil Procedure 11](https://www.law.cornell.edu/rules/frcp/rule_11) (checked 2026-10-22)
- [ABA Formal Opinion 512, Generative Artificial Intelligence Tools (29 July 2024)](https://www.americanbar.org/content/dam/aba/administrative/professional_responsibility/ethics-opinions/aba-formal-opinion-512.pdf) (checked 2026-10-22)

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*