Justia Class Action Opinion Summaries

by
A plaintiff purchased shares of a company that went public through a direct listing, which involved listing already-issued shares rather than issuing new ones. Following the listing, the company's stock price fell, and the plaintiff filed a class action lawsuit alleging that the registration statement was misleading, thus violating sections 11 and 12(a)(2) of the Securities Act of 1933. These sections impose strict liability for any untrue statement or omission of a material fact in a registration statement or prospectus.The district court denied the defendants' motion to dismiss, despite the plaintiff's concession that he could not trace his shares to the registration statement. The court held that it was sufficient for the plaintiff to allege that the shares were of the same nature as those issued under the registration statement. The Ninth Circuit initially affirmed this decision.The United States Supreme Court vacated the Ninth Circuit's decision, holding that section 11 requires plaintiffs to show that the securities they purchased were traceable to the particular registration statement alleged to be false or misleading. On remand, the Ninth Circuit concluded that section 12(a)(2) also requires such traceability. Given the plaintiff's concession that he could not make the required showing, the Ninth Circuit reversed the district court's decision and remanded with instructions to dismiss the complaint in full and with prejudice. View "PIRANI V. SLACK TECHNOLOGIES" on Justia Law

by
The case involves two homebuyers, Wynton Sanders and Tosha Lindsey, who entered into contracts with SM Landover, LLC and SM Parkside, LLC, respectively, for the purchase of new homes. Both contracts included provisions for deferred water and sewer charges and a one-year statute of limitations for bringing any claims related to the contracts. The homebuyers later filed class action complaints alleging that the sellers failed to disclose required information about the deferred charges, as mandated by Maryland law.The Circuit Court for Prince George’s County consolidated the cases for pretrial purposes and dismissed the complaints with prejudice. The court found that the sellers did not need to register as home builders because Stanley Martin Companies, LLC, a registered home builder, was also a party to the contracts. The court also concluded that the homebuyers’ claims accrued at the time of contracting, making them time-barred under the one-year contractual limitations period.The Appellate Court of Maryland affirmed in part and reversed in part. It held that the one-year contractual limitations period was reasonable and that the homebuyers’ claims accrued at the time of settlement, not contracting. Therefore, the claims were timely. However, the court also held that the sellers did not need to register as home builders because a registered home builder was a party to the contracts.The Supreme Court of Maryland reviewed the case and held that the homebuyers’ claims accrued at the time of contracting. The court also held that the sellers were required to register as home builders under Maryland law, even though a registered home builder was a party to the contracts. Consequently, the sellers could not enforce the one-year contractual limitations period, making the homebuyers’ claims timely. The court affirmed in part and reversed in part the judgment of the Appellate Court of Maryland. View "SM Landover LLC v. Sanders" on Justia Law

by
The City of East Lansing entered into an agreement with the Lansing Board of Water and Light (LBWL) in 2016, which included a franchise fee to be charged to LBWL consumers residing within the City. The fee was collected by LBWL and remitted to the City. Plaintiff James Heos, representing a class of LBWL consumers, filed a complaint against the City, alleging that the franchise fee was an illegal tax under the Michigan Constitution's Headlee Amendment and other state laws.The trial court granted summary disposition in favor of the plaintiff on most counts, ruling that the franchise fee was an illegal tax. The Michigan Court of Appeals reversed this decision, directing the trial court to grant summary disposition in favor of the City, concluding that the plaintiff was not a taxpayer and thus his claim was time-barred.The Michigan Supreme Court reviewed the case and held that the franchise fee was indeed a tax because it was used for general revenue-raising purposes, was not proportionate to any costs incurred by the City, and was not voluntary. The Court further held that the plaintiff was a taxpayer because the legal incidence of the fee fell on the LBWL consumers, not LBWL itself. The Court reversed the Court of Appeals' decision and remanded the case to the trial court for further proceedings, allowing the plaintiff to pursue his Headlee Amendment claim. View "Heos v. City Of East Lansing" on Justia Law

by
Nabors Corporate Services, Inc. (Nabors) performed oil well plug and abandonment work for the City of Long Beach (the City) between 2012 and 2014. The City had contracted with Tidelands Oil Production Company (Tidelands) for services on the Gerald Desmond Bridge Replacement Project, and Tidelands subcontracted the work to Nabors. The City and Tidelands had concluded that the work was not subject to prevailing wage laws, and Nabors was not informed otherwise during the bid process. After completing the work, Nabors faced a class action from its employees for unpaid prevailing wages, which led to arbitration awards and federal court judgments against Nabors.The Superior Court of Los Angeles County sustained demurrers by the City and Tidelands, dismissing Nabors’s claims for indemnity under Labor Code sections 1781 and 1784. The court ruled that section 1784 could not be applied retroactively to Tidelands and that the arbitration awards confirmed by the federal court did not qualify as court decisions under section 1781.The California Court of Appeal, Second Appellate District, Division Five, reviewed the case. The court affirmed the dismissal of the section 1784 claim against Tidelands, agreeing that the statute could not be applied retroactively. However, the court reversed the dismissal of the section 1781 claim against the City, holding that the federal court’s confirmation of arbitration awards did qualify as court decisions classifying the work as public work. The case was remanded with instructions to enter a new order overruling the City’s demurrer to the section 1781 cause of action. Nabors was awarded costs on appeal against the City, while Tidelands was awarded costs on appeal against Nabors. View "Nabors Corporate Services, Inc. v. City of Long Beach" on Justia Law

by
The Coachella Valley Water District (Water District) appealed a judgment finding that the rates it charged for Coachella Canal water violated Article XIII C of the California Constitution. The Water District argued that the rates were lawful and that no refund remedy was authorized. The court rejected both arguments, finding the rates unlawful and that a refund remedy was constitutionally mandated.In the lower court, the Superior Court of Riverside County ruled that the Water District's Canal Water rates and the Irrigation Water Availability Assessment (IWAA) violated Proposition 218. The court found that the Water District's historical priority argument was not persuasive and that the Water District had made no attempt to show that the rates complied with the California Constitution. The court deferred ruling on remedies and later awarded Class 2 customers approximately $17.5 million in refunds and interest for invalid charges from March 2018 through June 2022.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court held that Howard Jarvis Taxpayers Association (Howard Jarvis) had standing to challenge the Class 2 rates because domestic customers paid the rates indirectly. The court found that the Class 2 rates were taxes under Article XIII C and did not fall under any exceptions. The court rejected the Water District's arguments that the rates were justified based on historical priority and that they were expenditures of funds. The court also found that the IWAA was an assessment under Proposition 218 and that the Water District failed to show it was proportional to the benefits conferred on the properties.The court affirmed the lower court's ruling on liability and the amount of refund relief awarded. However, the court found that the injunction in the judgment was overbroad and modified the judgment to strike the paragraph enjoining the Water District from imposing any future Canal Water rates and charges that did not comply with Proposition 218. As modified, the judgment was affirmed, and Howard Jarvis was awarded its costs on appeal. View "Howard Jarvis Taxpayers Assn. v. Coachella Valley Water Dist." on Justia Law

by
Armando Guevara worked as a domestic service employee for Robert and Maria Zamora for over a decade, performing various tasks such as cleaning, car maintenance, and grocery shopping. Occasionally, he also provided services for the Zamoras' businesses, Lafise Corporation and Latin American Financial Services, Inc. (LAFS). Guevara was paid $1,365.88 biweekly, but there was no written employment agreement, and the parties disagreed on whether this amount represented a salary or an hourly wage. The Zamoras claimed they paid him an hourly rate with overtime, while Guevara asserted he was paid a salary without proper overtime compensation.Guevara filed a putative class action against the Zamoras, Lafise, and LAFS for unpaid overtime wages under the Fair Labor Standards Act (FLSA). The United States District Court for the Southern District of Florida granted summary judgment in favor of the defendants, finding that Guevara was not covered by the FLSA through either "enterprise coverage" or "individual coverage." The court also found that Guevara was fully compensated for all his overtime work hours based on the Zamoras' testimony and calculations.The United States Court of Appeals for the Eleventh Circuit reviewed the case and found that the district court erred in granting summary judgment. The appellate court determined that there was a genuine dispute regarding Guevara's regular hourly rate and, therefore, his overtime rate. The court noted that the Zamoras did not maintain accurate records, and the evidence presented created a genuine issue of fact that should be determined by a jury. The appellate court also vacated the district court's ruling on whether Lafise was a joint employer, as the lower court failed to provide sufficient reasoning and did not address the relevant factors. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Guevara v. Lafise Corp." on Justia Law

by
The plaintiffs, who are military members, filed a class action against Citibank, alleging violations of the Servicemembers Civil Relief Act (SCRA) and other statutes. They claimed Citibank improperly charged them higher interest rates and fees on their credit card balances after they left active duty, contrary to the SCRA's protections. The credit card agreements included arbitration clauses that required disputes to be resolved individually, not as class actions.The United States District Court for the Eastern District of North Carolina denied Citibank's motion to compel arbitration, holding that the SCRA allowed servicemembers to bring class actions in federal court despite any prior agreement to arbitrate. The court interpreted the SCRA's provision allowing class actions "notwithstanding any previous agreement to the contrary" as overriding the Federal Arbitration Act (FAA).The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court's decision. The Fourth Circuit held that the SCRA does not explicitly prohibit arbitration agreements and that the FAA requires enforcement of such agreements unless there is a clear congressional command to the contrary. The court found that the SCRA's language did not provide such a command and that the arbitration agreements should be enforced according to their terms, which included individual arbitration.The Fourth Circuit remanded the case with instructions to compel arbitration for all claims except those under the Military Lending Act (MLA). The court noted that the MLA explicitly prohibits arbitration agreements for disputes involving the extension of consumer credit to servicemembers. The district court was instructed to determine whether the MLA applied to the plaintiffs' credit card accounts and to address any related issues. View "Espin v. Citibank, N.A." on Justia Law

by
John Doe filed a putative class action against SSM Health Care Corporation in Missouri state court, alleging that SSM shared private health information with third-party marketing services without authorization, violating Missouri law. Doe claimed that SSM's MyChart patient portal transmitted personal health data to third-party websites like Facebook. The lawsuit included nine state law claims, such as violations of the Missouri Wiretap Statute and the Computer Tampering Act.SSM removed the case to federal court, citing the federal officer removal statute and the Class Action Fairness Act (CAFA). Doe moved to remand the case to state court. The United States District Court for the Eastern District of Missouri rejected SSM's arguments, ruling that SSM was not "acting under" a federal officer and that Doe's proposed class was limited to Missouri citizens, thus lacking the minimal diversity required under CAFA. The district court remanded the case to state court.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that SSM did not meet the criteria for federal officer removal because it was not acting under the direction of a federal officer. The court also held that the proposed class was limited to Missouri citizens, which destroyed the minimal diversity necessary for CAFA jurisdiction. Consequently, the Eighth Circuit affirmed the district court's remand order. View "Doe v. SSM Health Care Corporation" on Justia Law

by
Rebecca Petta filed a class-action complaint in the circuit court of Champaign County against Christie Business Holdings Company, P.C., doing business as Christie Clinic. Petta alleged that Christie negligently failed to prevent unauthorized access to its business email account, which potentially exposed patients' private personal data, including Social Security numbers and health insurance information. Christie moved to dismiss the complaint, and the trial court granted the motion.The trial court found that Petta had standing due to an inference of injury from unauthorized use of her phone number and city in a loan application. However, the court dismissed the complaint for failing to state a valid claim under existing law and due to the economic loss doctrine. The appellate court affirmed the dismissal but on the grounds that Petta lacked standing, as the alleged increased risk of identity theft was too speculative and the unauthorized loan application did not involve her private personal data.The Supreme Court of Illinois reviewed the case and agreed with the appellate court. The court held that Petta's allegations of increased risk of harm were insufficient to confer standing in a complaint seeking monetary damages. The court also found that the unauthorized loan application, which used only Petta's publicly available phone number and city, was not fairly traceable to Christie's alleged misconduct. Consequently, the court affirmed the appellate court's judgment, concluding that Petta lacked standing to bring her claims. View "Petta v. Christie Business Holding Co., P.C." on Justia Law

by
Plaintiffs, a class of individuals, filed mortgage foreclosure complaints in Illinois circuit courts and paid "add-on" filing fees mandated by section 15-1504.1 of the Code of Civil Procedure. They challenged the constitutionality of these fees, asserting that the statute violated the free access clause of the Illinois Constitution. The Illinois Supreme Court previously agreed, declaring the statute unconstitutional and affirming an injunction against its enforcement.The Will County circuit court initially certified the class and granted partial summary judgment, finding the statute unconstitutional. The appellate court reversed, and the case was remanded. On remand, plaintiffs pursued a refund of the fees. The circuit court dismissed the refund claim, citing sovereign immunity, which bars claims against the State. The appellate court reversed, holding that the circuit court had jurisdiction under the officer-suit exception to sovereign immunity, which allows suits against state officials for unconstitutional actions.The Illinois Supreme Court reviewed the case and held that while the officer-suit exception allowed the circuit court to enjoin the enforcement of the unconstitutional statute, it did not apply to the refund claim. The court determined that the refund claim was a retrospective monetary award to redress a past wrong, which falls under the jurisdiction of the Court of Claims, not the circuit court. Consequently, the Illinois Supreme Court reversed the appellate court's judgment and affirmed the circuit court's dismissal of the refund claim. View "Walker v. Chasteen" on Justia Law