Justia Class Action Opinion Summaries

The Health Care Authority for Baptist Health, an affiliate of UAB Health System ("HCA"), and The Health Care Authority for Baptist Health, an affiliate of UAB Health System d/b/a Prattville Baptist Hospital (collectively, "the HCA entities"), appealed a circuit court order denying their motion to compel arbitration in an action brought by Leonidas Dickson, II. In 2015, Dickson sustained injuries as a result of an automobile accident. Following the accident, Dickson was taken to Prattville Baptist Hospital ("PBH"), where he was treated and discharged. Dickson was partially covered by a health-insurance policy issued by Blue Cross and Blue Shield of Alabama, Inc. ("BCBS"). PBH was a party to a "Preferred Outpatient Facility Contract" ("the provider agreement") with BCBS, under which the medical care rendered to Dickson in the emergency department at PBH was reimbursable. In 2017, Dickson filed a complaint to challenge a reimbursement that PBH had received in exchange for Dickson's medical treatment. Dickson's complaint also sought to certify a class of people who were insured by BCBS and who had received care at any hospital operated by HCA's predecessor, Baptist Health, Inc. ("BHI"). After the HCA entities' motion to dismiss was denied, the HCA entities filed an answer to the lawsuit, but the answer did not raise arbitration as a defense. After a year of extensive discovery (including class certification and class-related discovery), the HCA entities moved to compel arbitration on grounds that Dickson's health-insurance policy with BCBS required all claims related to the policy to be arbitrated and that the provider agreement also provided for arbitration, contingent upon the arbitration requirements of the BCBS policy. The trial court denied the motion to compel without providing a reason for the denial. After a request for reconsideration was also denied, the HCA entities appealed. The Alabama Supreme Court concluded the HCA entities waived their right to arbitration, thus affirming the trial court order. View "The Health Care Authority for Baptist Health v. Dickson" on Justia Law

A facility caring for an unaccompanied child fails to provide a constitutionally adequate level of mental health care if it substantially departs from accepted professional standards. Appellants, a class of unaccompanied immigrant children detained at Shenandoah Valley Juvenile Center (SVJC), filed a class action alleging that the Commission fails to provide a constitutionally adequate level of mental health care due to its punitive practices and failure to implement trauma-informed care. The district court found that the Commission provides adequate care by offering access to counseling and medication.The Fourth Circuit held that neither the Flores Settlement nor SVJC's cooperative agreement prevent appellants from addressing their alleged injuries through the relief they seek from SVJC. On the merits, the court applied the Youngberg standard for professional judgment and reversed the district court's grant of summary judgment in favor of the Commission. The court explained that the district court incorrectly applied a standard of deliberate indifference when it should have determined whether the Commission substantially departed from accepted standards of professional judgment. Therefore, in light of the Youngberg standard, the district court must consider evidence relevant to the professional standards of care necessary to treat appellants' serious mental health needs. The court left it to the district court to determine in the first instance to what extent, if any, the trauma-informed approach should be incorporated into the professional judgment standard in this particular case. Accordingly, the court remanded for further proceedings. View "Doe v. Shenandoah Valley Juvenile Center Commission" on Justia Law

Plaintiffs filed a class action against CPAY, alleging breach of contract, state-law fraudulent concealment, and violation of the Racketeer Influenced and Corrupt Organizations Act (RICO). Plaintiffs, a class of over 160,000 small retailers using CPAY for credit card processing, allege that CPAY misrepresented a number of fees, added fees with no value to retailers, and inflated fees without prior approval from issuing banks.The Eighth Circuit affirmed the district court's certification of the proposed class, holding that the district court engaged in a sufficiently rigorous analysis of Federal Rule 23 certification and made specific findings of fact. The court also held that the district court did not err in determining that common questions predominate; that plaintiffs' claims are typical of class members; and that plaintiffs will represent class interests adequately. Finally, the district court did not abuse its discretion in finding that a class action is the superior mechanism to try this case. View "Custom Hair Designs by Sandy v. Central Payment Co." on Justia Law

The Supreme Court affirmed the trial court's order regarding class certification in this case and dismissed Defendants' interlocutory appeal regarding portions of the trial court's order that pertained to discovery matters, holding that the superior court did not abuse its discretion in certifying two classes of plaintiffs.Plaintiffs commenced a putative class action by asserting claims against Defendants, Orange County and the Town of Chapel Hill, seeking to recover impact fees assessed under a now-repealed statute that had been enacted to allow certain counties and municipalities to defray the costs for constructing, among other public services, public schools. The trial court certified two classes of plaintiffs. Defendants appealed, challenging the class certification and a discovery order concerning Plaintiffs' motion to compel discovery responses. The Supreme Court affirmed in part and dismissed in part, holding (1) the trial court did not err in certifying the classes; and (2) Defendants' effort to appeal the contested discovery ruling was premature and hence must be dismissed for lack of appellate jurisdiction. View "Zander v. Orange County" on Justia Law

The Cook County Jail houses primarily people who have not yet been convicted. Under the jail’s “paper triage” policy, a detainee who has dental pain and wants treatment must submit a health service request form (HSRF). Staff review the HSRF and categorize it as “routine,” “priority,” or “urgent.” The detainee is referred to a dentist for treatment in three to 30 days, depending on the categorization. Most detainees do not receive a face-to-face assessment from a nurse or higher-level practitioner before they see a dentist. An assessment could identify bona fide complaints of dental pain or reveal serious medical issues and would allow a nurse to dispense over-the-counter pain medication.McFields, a former detainee, filed a putative class action, alleging that detainees suffered gratuitous pain as a result of the paper triage policy. They alleged that the standard of care for processing a health service request requires a face-to-face assessment within 48 hours and that the jail’s policy is objectively unreasonable. The Seventh Circuit affirmed the denial of class certification, noting that each detainee presents a different situation that involved a different type of pain, took place at a different time, and involved different medical professionals and prison staff. McFields failed to satisfy the commonality and typicality requirements of Rule 23. Individual issues predominate over common questions. View "McFields v. Dart" on Justia Law

Plaintiff appealed the trial court's grant of summary judgment in favor of Staples. The Court of Appeal held that the trial court erred in applying the class action tolling rules articulated in Jolly v. Eli Lilly & Co. (1988) 44 Cal.3d 1103. The court explained that plaintiff was entitled, due to the pendency of the Wesson and Hatgis class certification proceedings, to claim the benefit of the class action tolling rule established by the United States Supreme Court in American Pipe & Construction Co. v. Utah (1974) 414 U.S. 538, as adopted by Jolly. Therefore, with the exception of the claim for failure to furnish accurate itemized wage statements, the trial court erred in ruling that plaintiff's claims were time barred. In this case, because plaintiff concedes his claim for failure to furnish accurate itemized wage statements is time barred, even if tolling applies, the court affirmed the summary adjudication of that claim. The court reversed summary judgment in all other respects. View "Hildebrandt v. Staples the Office Superstore, LLC" on Justia Law

The Tampa Bay Buccaneers were sued in at least five class action complaints, each one alleging that the Buccaneers sent telefax advertisements in violation of the Telephone Consumer Protection Act (TCPA). In one class action, lawyers from the AW Firm, who had previously filed suit on behalf of a different plaintiff, added another class action representative, M&C. Shortly after an unsuccessful mediation was conducted, defendant, an attorney at the AW Firm who was principally involved in the mediation, left the firm to join the Bock Firm. The Bock Firm then filed a separate class action against the Buccaneers, which resulted in a proposed settlement.M&C then filed suit against the Bock Firm in state court, alleging that they had breached fiduciary duties owed to it as a named class representative. M&C and its counsel claimed that defendant gave attorneys at the Bock Firm confidential information about settlement negotiations in the AW Firm's class action, which assisted the Bock Firm in settling their class action quickly and to the detriment of the class. The district court granted summary judgment for defendant and the Bock Firm.The Eleventh Circuit held that the duties owed to a class representative do not differ from the duties owed to a class. The court also clarified the duties owed by class counsel in class actions generally and in the context of this case specifically. In this case, the court determined that in filing this action M&C and a principal at the AW Firm launched an impermissible collateral attack on the Bock Firm's attempt to certify and settle a class action. The court explained that their assertions should have been made only before the court that was exercising jurisdiction over the Rule 23 putative class action — the court in which the request to certify a settlement class and approve the settlement was made. The court found no error in the district court's determination that M&C failed to establish that it was damaged by any alleged breach of a fiduciary duty owed to it by defendant. Accordingly, the court affirmed the district court's grant of summary judgment in favor of defendant and the Bock Firm. View "Medical & Chiropractic Clinic, Inc. v. Oppenheim" on Justia Law

The Supreme Court granted as moulded a petition for writ of prohibition sought by Respondent to prohibit the circuit court from conducting any further proceedings in this case until the circuit court vacated its class certification order, holding that the circuit court exceeded its jurisdiction by failing to conduct an appropriate and thorough analysis of the West Virginia Rules of Civil Procedure 23(a) and 23(b) class certification requirements.Respondent, the Honorable Thomas A. Bedell, sitting by assignment as a circuit court judge, certified a class action against Petitioner. Petitioner subsequently filed the instant petition seeking to prohibit enforcement of the class certification order, asserting that the circuit court clearly erred in several respects in certifying the class action. The Supreme Court agreed, holding that the circuit court exceeded its legitimate powers by certifying the class without undertaking a thorough analysis in its determination of whether the class certification requirements of W. Va. R. Civ. P. 23 were satisfied. View "State ex rel. Surnaik Holdings of West Virginia, LLC v. Honorable Thomas Bedell" on Justia Law

The Ninth Circuit affirmed the district court's denial of plaintiff's motion to certify a class in a dispute regarding the proper method of calculating overtime wages under California law. Plaintiff sought to represent a class of more than 5,000 hourly-paid, non-managerial call center workers in California for numerous wage and hour violations allegedly committed by BOA.The panel held that plaintiff has established commonality; plaintiff has established the typicality of her claim; but plaintiff has not established predominance, which was essential to her class action claim. In this case, the challenged BOA policy either did not apply or did not cause an injury to many employees. View "Castillo v. Bank of America, NA" on Justia Law

The Ninth Circuit affirmed the district court's decision to remand the class action to state court because defendant based the claimed amount in controversy on unreasonable assumptions. Plaintiff filed a class action against his former employer, KMI, alleging that KMI violated several provisions of the California Labor Code.The panel held that KMI failed to sufficiently demonstrate that it met the Class Action Fairness Act's requirement that the amount in controversy exceed $5 million. The panel explained that, once plaintiff contested the reasonableness of KMI's assumptions, KMI had the burden of proving by a preponderance of the evidence that its assumptions were reasonable. The court concluded that KMI did not carry its burden because it relied on assumptions regarding the Meal Period and Rest Period subclasses that were unreasonable. In this case, KMI failed to provide any evidence to support its assumption that all 442 Hourly Employee Class members were the same as the members of the Meal Period Sub-Class or the Rest Period Sub-Class or that they all worked shifts long enough to qualify for meal or rest periods. Finally, a remand to the district court for further factfinding is not required. View "Harris v. KM Industrial, Inc." on Justia Law