Justia Class Action Opinion Summaries

Retired employees of two companies, who participated in their employers’ defined benefit pension plans, brought class action lawsuits alleging violations of the Employee Retirement Income Security Act (ERISA). These plaintiffs, all married, claimed that their plans calculated joint and survivor annuity benefits using mortality tables based on outdated data from the 1960s and 1970s. Because life expectancies have increased since then, the plaintiffs asserted that using such outdated mortality assumptions improperly reduced their benefits, resulting in joint and survivor annuities that were not the actuarial equivalent of the single life annuities to which they would otherwise be entitled, as required by ERISA.Each group of plaintiffs filed suit in federal district court—one in the Eastern District of Michigan against the Kellogg plans and one in the Western District of Tennessee against the FedEx plan—asserting that the use of obsolete actuarial assumptions violated 29 U.S.C. § 1055(d) and constituted a breach of fiduciary duty under ERISA. The district courts in both cases dismissed the complaints for failure to state a claim, holding that ERISA does not require use of any particular mortality table or actuarial assumption in calculating benefits for married participants, and thus the allegations, even if true, did not establish a violation.The United States Court of Appeals for the Sixth Circuit reviewed the dismissals de novo. The court held that, under ERISA’s statutory requirement that joint and survivor annuities be “actuarially equivalent” to single life annuities, plans must use actuarial assumptions, including mortality data, that reasonably reflect the life expectancies of current participants. The court concluded that plaintiffs had plausibly alleged that the use of outdated mortality tables was unreasonable and could violate ERISA. Accordingly, the Sixth Circuit reversed the district courts’ judgments and remanded both cases for further proceedings. View "Reichert v. Kellogg Co." on Justia Law

An assisted living residence operated by the defendant charged new residents a one-time “community fee” upon admission. The agreement stated that this fee was intended to cover upfront staff administrative costs, the resident’s initial service coordination plan, move-in assistance, and to establish a reserve for building improvements. The plaintiff, acting as executor of a former resident’s estate and representing a class, alleged that this community fee violated the Massachusetts security deposit statute, which limits the types of upfront fees a landlord may charge tenants. The complaint further claimed that charging the fee was an unfair and deceptive practice under state consumer protection law.The Superior Court initially dismissed the case, finding that the security deposit statute did not apply to assisted living residences, which are governed by their own regulatory scheme. On appeal, the Supreme Judicial Court of Massachusetts previously held in a related decision that the statute does apply to such residences when acting as landlords, but does not prohibit upfront fees for services unique to assisted living facilities. The court remanded the case for further factual development to determine whether the community fee corresponded to such services. After discovery and class certification, both parties moved for summary judgment. The Superior Court judge ruled for the plaintiffs, finding that the community fees were not used solely for allowable services because they were deposited into a general account used for various expenses, including non-allowable capital improvements.On direct appellate review, the Supreme Judicial Court of Massachusetts reversed. The court held that the defendant was entitled to judgment as a matter of law because uncontradicted evidence showed that the community fees corresponded to costs for assisted living-specific intake services that exceeded the amount of the fees collected. The court emphasized that the statute does not require the fees to be segregated or tracked dollar-for-dollar, and ordered judgment in favor of the defendant. View "Ryan v. Mary Ann Morse Healthcare Corp." on Justia Law

Two former employees of a financial services company, each a participant in the employer’s defined contribution retirement plan, sued the company on behalf of themselves and other similarly situated plan participants. They alleged that the company, as plan sponsor and fiduciary, breached its duties under the Employee Retirement Income Security Act (ERISA) by selecting and retaining certain BlackRock LifePath Index Funds as investment options, which they claimed were imprudent and caused monetary losses to their individual plan accounts. The plaintiffs sought recovery of losses under ERISA sections 502(a)(2) and 409(a).The United States District Court for the Eastern District of Virginia denied the defendant’s motion to dismiss most of the claims, holding that the plaintiffs plausibly alleged a breach of fiduciary duty. It then certified a class of all plan participants and beneficiaries with investments in the BlackRock funds during the relevant period, under Federal Rule of Civil Procedure 23(b)(1), finding that ERISA fiduciary-duty claims are inherently suitable for class treatment because they are brought on behalf of the plan and that allowing individual suits would risk inconsistent standards or impair interests of absent participants. The district court also found that the commonality requirement of Rule 23(a)(2) was satisfied.On interlocutory appeal, the United States Court of Appeals for the Fourth Circuit reversed and vacated the class certification order. The Fourth Circuit held that, in the context of a defined contribution plan, claims under ERISA § 502(a)(2) for monetary losses to individual accounts are inherently individualized and cannot be joined in a mandatory class under Rule 23(b)(1), which does not provide for notice or opt-out rights. The court also held that the claims failed to satisfy the commonality prerequisite because many class members did not experience the same injury. The district court’s order was thus reversed and vacated. View "Trauernicht v. Genworth Financial Inc." on Justia Law

Several employees of United Airlines challenged the company's COVID-19 vaccine mandate, alleging that United failed to provide reasonable religious and medical accommodations, in violation of Title VII of the Civil Rights Act of 1964 and the Americans with Disabilities Act (ADA). United required all U.S. employees to be vaccinated by specific deadlines unless granted a religious or medical exemption. Employees seeking a religious accommodation needed to provide a personal statement of belief and a third-party attestation; those seeking a medical exemption had to submit supporting medical documentation. United initially planned to place all exempted employees on unpaid leave but later revised its policy for non-customer-facing employees, allowing them to work with masking and testing requirements, while customer-facing employees remained on indefinite unpaid leave.The United States District Court for the Northern District of Texas considered and partially granted the plaintiffs’ motion for class certification. The district court rejected a class seeking injunctive relief under Rule 23(b)(2) and a subclass of employees subject to masking and testing requirements, finding that the proposed classes lacked commonality and predominance due to the individualized nature of harm and the need for separate inquiries into the circumstances of each member. The court certified a modified subclass under Rule 23(b)(3) consisting of religious-accommodation seekers who were placed on unpaid leave but excluded those with medical accommodations from the subclass.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the class certification order under an abuse of discretion standard. The Fifth Circuit affirmed the district court’s decision, holding that the district court did not abuse its discretion in rejecting the broader classes and subclasses due to the individualized nature of the claims and in certifying the subclass of religious-accommodation seekers placed on unpaid leave. The court found that common questions predominated and that a class action was a superior method of adjudication for that subclass. View "Sambrano v. United Airlines" on Justia Law

In the fall of 2025, federal immigration authorities increased enforcement activities in Chicago through “Operation Midway Blitz,” prompting protests near an Immigration and Customs Enforcement (ICE) detention center in Broadview, Illinois. Protesters and journalists alleged that federal officers from ICE, Customs and Border Protection (CBP), and the Department of Homeland Security (DHS) violated their First and Fourth Amendment rights by deploying tear gas and other chemical agents without justification. The plaintiffs described instances of excessive force and sought injunctive relief to stop such practices.The United States District Court for the Northern District of Illinois issued a temporary restraining order and later a broad preliminary injunction that applied districtwide, enjoining all federal law enforcement officers and agencies from using certain crowd control tactics. The court also certified a plaintiff class and required ongoing compliance reporting from DHS officials. The government appealed the preliminary injunction, arguing it was overbroad and infringed on separation of powers principles. The United States Court of Appeals for the Seventh Circuit stayed the injunction, citing its expansive scope and concerns over standing.Subsequently, as the enforcement operation ended and no further constitutional violations were reported, the plaintiffs moved to dismiss the case. The district court dismissed the case without prejudice and decertified the class, contrary to the plaintiffs’ request for dismissal with prejudice. On appeal, the United States Court of Appeals for the Seventh Circuit found that extraordinary circumstances warranted vacating the district court’s preliminary injunction. The Seventh Circuit held that vacatur was appropriate because the case had become moot and to prevent the now-unreviewable injunction from producing adverse legal consequences in future litigation. The court vacated the injunction and dismissed the appeal. View "Chicago Headline Club v. Noem" on Justia Law

Two individuals each owned companies that distributed snack foods for a larger food company. Years earlier, they had joined a class action lawsuit claiming that the company misclassified them as independent contractors rather than employees. That class action ended in a settlement, which included an optional provision: class members could agree to arbitrate future disputes in exchange for an additional payment. Both individuals opted into that provision and accepted the payment, thereby agreeing to resolve future disputes through arbitration.Several years later, the two individuals brought a new lawsuit in the United States District Court for the District of Massachusetts, again asserting claims related to alleged misclassification and seeking damages. The defendant company moved to stay the case and compel arbitration under the Federal Arbitration Act (FAA), citing the prior agreement. The plaintiffs opposed, arguing that they were exempt from the FAA as transportation workers under Section 1. The district court rejected that exemption argument, but did not order arbitration. Instead, it stayed and administratively closed the case without entering judgment, stating it was not compelling arbitration but was closing its doors to further proceedings.The United States Court of Appeals for the First Circuit reviewed the district court’s handling. The court held that, although the district court did not expressly deny the motion to compel arbitration, its actions amounted to a denial, and thus appellate jurisdiction existed under 9 U.S.C. § 16(a)(1)(B). The First Circuit vacated the district court’s order and remanded the case for further proceedings, directing the district court to determine whether the motion to compel arbitration should be granted or denied and to explain its reasoning. The court also clarified that, under the parties’ agreement, any compelled arbitration must proceed on an individual, not class, basis. View "Perruzzi v. The Campbell's Company" on Justia Law

After receiving a letter from a debt collector that she believed was misleading and threatening, an individual felt confused and feared potential legal action. She consulted an attorney and then initiated a putative class action lawsuit, seeking damages for herself and similarly situated Wisconsin consumers under both federal and state consumer protection statutes. The alleged violation centered on the misleading nature of the debt collection letter and its implications regarding possible litigation. After some discovery, she elected to pursue monetary damages for a putative class under the Wisconsin Consumer Act and sent the debt collector a statutory notice and demand.In response, the debt collector offered the individual actual damages and the maximum statutory penalty, and promised to cease sending similar collection letters, offering this as “an appropriate remedy.” The individual rejected the offer and moved for class certification. The Milwaukee County Circuit Court granted class certification, reasoning that the statutory provision required an appropriate remedy to be offered to the whole class, not just the named plaintiff. The court concluded that allowing a defendant to “pick off” the class representative would undermine the purpose of class actions under the Wisconsin Consumer Act. The Wisconsin Court of Appeals affirmed, focusing on the public policy interests underlying class actions.The Supreme Court of Wisconsin reviewed the case. The court held that under Wis. Stat. § 426.110(4)(c), when a customer initiates a class action for damages, the statute requires that an appropriate remedy be given to the party bringing suit—not the putative class—within 30 days after notice. If the party plaintiff receives or is promised an appropriate remedy, a class action for damages cannot be maintained. Accordingly, the Supreme Court reversed the decision of the court of appeals and remanded for further proceedings. View "Gudex v. Franklin Collection Service, Inc." on Justia Law

Two Ohio homeowners discovered that their personal information, including their names, addresses, and property details, appeared in paid reports on a real estate research website operated by a company. The website allows users to search for property information by address or owner name and provides one free report per user, with additional reports available for purchase. The homeowners, without having consented to the use of their information, filed a class action lawsuit on behalf of similarly situated individuals, alleging that the company violated their rights of publicity under both Ohio statute and common law by using their identities for commercial gain.The United States District Court for the Northern District of Ohio reviewed the case after the company moved to dismiss for failure to state a claim. The district court granted the motion and dismissed the complaint with prejudice, finding that the plaintiffs had not adequately alleged that their identities possessed independent commercial value—a necessary element of a right of publicity claim under Ohio law.On appeal, the United States Court of Appeals for the Sixth Circuit conducted a de novo review. It affirmed the district court's dismissal, holding that the plaintiffs failed to plead facts showing that their names or identities had any commercial value, as required by both Ohio’s statutory and common law right of publicity. The court reasoned that simply being used in a commercial context does not satisfy the commercial value requirement, relying on both prior circuit precedent and Ohio state court decisions. The court also declined to certify a question of law to the Ohio Supreme Court, concluding that Ohio law on this issue was sufficiently settled. The judgment of the district court was affirmed. View "LaFleur v. Yardi Systems, Inc." on Justia Law

Two workers filed a putative class action against several contractors and subcontractors, alleging that they performed work on public works projects and were not paid overtime at the prevailing wage rates required by Nevada law. Their lawsuit sought damages equal to the difference between what they were paid and the higher amounts allegedly owed under Nevada’s prevailing-wage statute for both regular and overtime work. The plaintiffs also asserted, in the alternative, that they could recover these amounts under Nevada’s more general wage-and-hour provisions or as third-party beneficiaries of the relevant public works contracts. The complaint did not specify which public works projects were involved or allege that the plaintiffs had pursued administrative remedies through the Nevada Labor Commissioner.The case was first reviewed by the Eighth Judicial District Court in Clark County. The defendants moved to dismiss the complaint on the basis that the plaintiffs had not alleged exhaustion of the administrative remedies required under Nevada’s prevailing-wage law. The district court granted the motion to dismiss, ruling that there was no private right of action for wage claims under the prevailing-wage statute and that the alternative claims were derivative and failed for the same reason. The court also denied the plaintiffs’ motion for leave to amend the complaint, finding that amendment would be futile.On appeal, the Supreme Court of the State of Nevada affirmed the district court’s decision. The court held that NRS Chapter 338, Nevada’s prevailing-wage statute, does not provide a private right of action to employees outside the administrative process it creates. Claims for violation of the statute must first be brought through the administrative mechanisms with the Labor Commissioner, and cannot be circumvented by recasting them under other wage-and-hour laws or as third-party beneficiary claims. The court also found no error in denying leave to amend the complaint. View "STUCKEY VS. APEX MATERIALS, LLC" on Justia Law

Bradford entered into a service agreement with a Texas-based pest control company, Sovereign Pest Control, and as part of this agreement, provided his cell phone number to the company. Bradford later acknowledged that he gave his number so the company could contact him if needed. During their business relationship, Sovereign Pest made several pre-recorded calls to Bradford’s cell phone, including calls to schedule renewal inspections, after which Bradford scheduled inspections and renewed his service plan multiple times.Bradford initiated a putative class-action lawsuit in the United States District Court for the Southern District of Texas, alleging that Sovereign Pest violated the Telephone Consumer Protection Act of 1991 (TCPA) by sending him unsolicited pre-recorded calls without his “prior express written consent.” The district court granted summary judgment for Sovereign Pest, holding that the calls did not constitute telemarketing and that Bradford had given prior express consent. Bradford appealed, arguing that the calls were telemarketing and that he had not given the required consent.The United States Court of Appeals for the Fifth Circuit reviewed the summary judgment de novo and affirmed the district court’s decision. The appellate court held that the TCPA only requires “prior express consent,” which can be either oral or written, for any pre-recorded call to a wireless number, regardless of whether the call is telemarketing or informational. The court found that Bradford had provided prior express consent by voluntarily giving his cell phone number to the company in connection with the service agreement and by his subsequent conduct. It concluded that the statute does not require “prior express written consent” for telemarketing calls and that Bradford’s arguments to the contrary were unavailing. The Fifth Circuit therefore affirmed summary judgment in favor of Sovereign Pest. View "Bradford v. Sovereign Pest" on Justia Law