Following Roes, 1-2 v. SFBSC Management, LLC (9th Cir. 2019) 944 F.3d 1035, this decision holds that when a class action settles before class certification, the district court may not apply a presumption of fairness to the settlement based on arms-length negotiation between experienced counsel. Instead, the court mus employ extra caution and more rigorous scrutiny in evaluating a pre-certification settlement. This heightened scrutiny is required even if the plaintiff previously moved unsuccessfully for class certification. The decision also holds that the usual rule requiring an objector to state in the district court the ground on which he seeks reversal on appeal does not apply when the issue arises for the first time in the district court’s final order, as the improper application of a presumption of fairness did here.