A federal judge has blasted plaintiffs and counsel, breaking with the long-standing reticence of judges to reject class certification based on allegedly improper solicitation of clients, and raising hopes among the defense bar that this will spark a trend.

Recently, U.S. District Judge Marilyn Hall Patel in San Francisco rejected class certification and castigated the plaintiffs’ lawyer for what she called unethical conduct in allegedly manufacturing a case, then finding a plaintiff in a suit against Oreck Direct LLC, a maker of air purifiers.