Though it did most other things right, the district court erred in expressly employing the wrong standard to decide whether the class action settlement in this case was fair, just, and equitable.  In a pre-certification settlement, like this one, the district court may not presume the settlement is reasonable but must instead exercise heightened scrutiny.  Application of the wrong standard is an abuse of discretion requiring the order approving the class settlement to be vacated along with the attorney fee and individual plaintiff incentive payment awards.