Justia Class Action Opinion Summaries
Villarroel v. Recology
This case revolves around the filed rate doctrine and its applicability in instances where rates approved by a municipal board are questioned. The plaintiffs, a group of customers, sued Recology, a waste management company, alleging that the company violated the Unfair Competition Law and other laws by bribing a city official to facilitate the approval of Recology’s application for increased refuse collection rates. The trial court ruled in favor of Recology, holding that the claims were barred by the filed rate doctrine. The Court of Appeal of the State of California First Appellate District Division Three reversed the decision, stating that the California version of the filed rate doctrine does not bar this action because the purposes underlying the doctrine – “nondiscrimination” and “nonjusticiability” strands – are not implicated by plaintiffs’ claims. The court also concluded that the judgment in the prior law enforcement action does not pose a res judicata bar to this putative class action. The court remanded the case for the trial court’s consideration of Recology’s remaining challenges in the first instance. View "Villarroel v. Recology" on Justia Law
Pinkston v. City of Chicago
The Municipal Code of Chicago included provisions concerning public parking, including parking meters. The fine for exceeding the time purchased at a parking meter differs depending on whether the violation occurs in the “central business district” or the “non-central business district.” At the time of the alleged violation, failure to comply with the parking meter regulations in the central business district resulted in a $65 fine. A $50 fine applied to similar violations outside the central business district.Pinkston filed a class-action, alleging that Chicago had engaged in the routine practice of improperly issuing central business district tickets for parking meter violations. The circuit court dismissed for failure to exhaust administrative remedies before the Chicago Department of Administrative Hearings and voluntarily paying his fine. The appellate court reversed. The Illinois Supreme Court reinstated the dismissal. The underlying issue—whether Pinkston received an improper parking ticket—is routinely handled at the administrative level; an aggrieved party cannot circumvent administrative remedies “by a class action for declaratory judgment, injunction or other relief.” View "Pinkston v. City of Chicago" on Justia Law
BRANDON BRISKIN V. SHOPIFY, INC., ET AL
Plaintiff is a resident of California. While present in California, Plaintiff used his iPhone’s Safari browser to navigate to the website of California-based retailer IABMFG to purchase fitness apparel. Although Plaintiff claims he did not know it at the time, IABMFG’s website used software and code from Shopify, Inc. to process customer orders and payments. Shopify, Inc. is a Canadian corporation with its headquarters in Ottawa, Canada. Plaintiff filed a putative class action lawsuit in California alleging that Shopify violated various California privacy and unfair competition laws because it deliberately concealed its involvement in consumer transactions. The district court agreed, dismissing the second amended complaint without leave to amend. Plaintiff timely appealed. The Ninth Circuit affirmed. For specific jurisdiction to exist over Shopify, Plaintiff’s claim must arise out of or relate to Shopify’s forum-related activities. The panel held that there was no causal relationship between Shopify’s broader business contacts in California and Plaintiff’s claims because these contacts did not cause Plaintiff’s harm. Nor did Plaintiff’s claims “relate to” Shopify’s broader business activities in California outside of its extraction and retention of plaintiff’s data. Because there was an insufficient relationship between plaintiff's claims and Shopify’s broader business contacts in California, the activities relevant to the specific jurisdiction analysis were those that caused Plaintiff’s injuries: Shopify’s collection, retention, and use of consumer data obtained from persons who made online purchases while in California. The panel held that Shopify, which provides nationwide web-based payment processing services to online merchants, did not expressly aim its conduct toward California. View "BRANDON BRISKIN V. SHOPIFY, INC., ET AL" on Justia Law
Robert Ponzio, et al v. Emily Pinon, et al v.
Mercedes-Benz USA and Daimler AG have sold and leased a number of different Mercedes-Benz vehicles painted in a color called 590 Mars Red. Either due to a defect in the paint or some other reasons the paint on some of these vehicles has deteriorated. Emily Pinon is the owner/lessee of a Mercedes-Benz vehicle painted in Mars Red. Ms. Pinon asserted numerous claims under federal and state law. The third amended class action complaint, the operative pleading, named six other individuals as plaintiffs: (collectively the “Pinon plaintiffs”). The Pinon plaintiffs submitted a motion for preliminary approval of the proposed class action settlement agreement and preliminary certification of the nationwide settlement. Collaboration between the Pinon plaintiffs and the plaintiffs in the District of New Jersey action (collectively the “Ponzio objectors”) failed. The district court rejected the contention of the Ponzio objectors that the settlement agreement failed to provide benefits to the great majority of the class members. The Eleventh Circuit affirmed. The court held that the district court did not abuse its discretion in approving the class action settlement. The court explained that it rejects the Ponzio objectors’ argument that “the economic interests of substantial portions of the [c]lass [m]embers are in substantial conflict” and the “interests of the [Pinon] class representatives are not aligned with, and are actually antagonistic to, the interests of a majority of [c]lass [m]embers. The court explained that it was satisfied that the district court took the objections of the Ponzio objectors seriously and, after rejecting those objections, acted within its discretion in approving the settlement agreement. View "Robert Ponzio, et al v. Emily Pinon, et al v." on Justia Law
Hardwick v. 3M Co.
Hardwick alleged that his bloodstream contains trace quantities of five chemicals (PFAS)—which are part of a family of thousands of chemicals used in medical devices, automotive interiors, waterproof clothing, food packaging, firefighting foam, non-stick cookware, ski and car waxes, batteries, semiconductors, aviation and aerospace construction, paints and varnishes, and building materials. Hardwick, who was exposed to firefighting foam, does not know what companies manufactured the particular chemicals in his bloodstream; nor does he know whether those chemicals might someday make him sick. Of the thousands of companies that have manufactured PFAS since the 1950s, Hardwick sued 10 defendants and sought to represent a class comprising nearly every person “residing in the United States.” The district court certified a class comprising every person residing in Ohio with trace amounts of certain PFAS in their blood.The Sixth Circuit remanded with instructions to dismiss the case. Even at the pleadings stage, the factual allegations, taken as true, “must be enough to raise a right to relief above the speculative level.” The element of traceability requires a showing that the plaintiff’s “injury was likely caused by the defendant.” The district court treated the defendants as a collective, but “standing is not dispensed in gross.” Even if Hardwick met the actual-injury requirement he must tie his injury to each defendant.” Hardwick’s conclusory allegations do not support a plausible inference that any of the defendants bear responsibility for the PFAS in Hardwick’s blood. View "Hardwick v. 3M Co." on Justia Law
James v. Hegar
Plaintiffs are three Texas residents whose assets escheated to the State under Texas’s Unclaimed Property Act. Plaintiffs brought a class action lawsuit against the Texas Comptroller and a director in the Comptroller’s office, alleging that the State is abusing the Unclaimed Property Act to seize purportedly abandoned property without providing proper notice. The district court dismissed most of Plaintiffs’ claims. Defendants contend that Plaintiffs cannot invoke Ex parte Young because they lack standing to seek prospective relief and have not alleged an ongoing violation of federal law. The Fifth Circuit agreed with Defendants and reversed the district court’s denial of Eleventh Amendment sovereign immunity, and remanded with instructions to dismiss Plaintiffs’ remaining claims for prospective relief without prejudice. The court explained that Plaintiffs have failed to allege facts indicating that Texas’s alleged abuse of the UPA is ongoing or will continue in the future. As there is no ongoing violation of federal law sufficiently pleaded in the complaint, Plaintiffs have failed to satisfy the Ex parte Young requirements, and their claims for prospective relief are barred by sovereign immunity. View "James v. Hegar" on Justia Law
In re Ford Motor Co.
A putative class sued Ford over an alleged design defect in their F-150 pickup trucks, model years 2013-2018, involving brake master cylinders manufactured by Hitachi, citing two alternative theories of how the failure of internal seals would occur. The court declined to certify injunction and damages classes under Federal Rule of Civil Procedure 23(b)(2) and (b)(3) but certified five statewide issue classes under 23(c)(4) for three issues: whether the brake systems were defective; whether Ford possessed pre-sale knowledge of the defect; and whether concealed information about the defect would be material to a reasonable buyer.On interlocutory review, the Sixth Circuit reversed. Rule 23 certification requires that a class action be able to “generate common answers apt to drive the resolution of the litigation.” Here, it is not clear that the certified issues can each be answered “in one stroke.” The court noted design and manufacturing changes to the units over the years and that the class alleged two distinct theories of design defect. Ford may have believed any problem was fixed when Hitachi altered its cylinder design. It is possible that those changes affected brake performance to a degree that would have made a difference to a consumer. On remand, the district court must evaluate whether each of the four Rule 23(a) factors is actually satisfied, not merely properly alleged. The inquiry might overlap with the merits of the underlying claims but is a crucial part of avoiding the procedural unfairness to which class actions are uniquely susceptible. View "In re Ford Motor Co." on Justia Law
Reliance Health Care, Inc. v. Mitchell
The Supreme Court dismissed this interlocutory appeal of a vacated class certification order and directed the circuit court to remand the case to address motions to compel arbitration, holding that this appeal was moot.Plaintiffs, who represented the estates of former residents of fourteen different nursing homes, alleged breach of contract and unjust enrichment claims against the nursing homes, in violation of the Arkansas Civil Rights act and the Arkansas Deceptive Trade Practices Act. The nursing homes moved to compel arbitration for all but two of the named plaintiffs, after which the plaintiffs moved for class certification. The circuit court granted Plaintiffs' motion for class certification without ruling on the motions to compel arbitration. The nursing homes brought an interlocutory appeal of the class-certification order and petitioned for writ of prohibition, mandamus, and certiorari. The Supreme Court granted the writ petition, vacating the order granting class certification, and ordered the circuit court to rule on the motions to compel before ruling on class certification, holding that the interlocutory appeal of the vacated class-certification order was moot. View "Reliance Health Care, Inc. v. Mitchell" on Justia Law
Sepanossian v. Nat. Ready Mix Co.
Gary Sepanossian, dba G.S. Construction (Sepanossian), individually and as class representative, filed a class action against National Ready Mix Concrete Co., Inc. (Ready Mix), alleging Ready Mix charged its customers an “energy” fee and an “environmental” fee “wholly untethered to any actual cost for ‘energy’ or ‘environmental’ issues” that Ready Mix instead “recognize[s] as profit.” The complaint alleges causes of action for (1) violation of California’s Unfair Competition Law (UCL) under the fraudulent and unfair business practices prongs; (2) breach of contract; and (3) “unjust enrichment.” After Ready Mix answered the complaint, Sepanossian filed a motion for class certification. The trial court granted class certification but expressed doubts about Sepanossian’s legal claims and invited the parties to present a motion for judgment on the pleadings to address the merits before class notice. The parties agreed to do so, and Ready Mix subsequently filed a motion for judgment on the pleadings, which the trial court granted on the UCL and unjust enrichment causes of action. The Second Appellate District reversed because Sepanossian alleged facts sufficient to state a cause of action under the UCL but affirmed dismissal of the unjust enrichment cause of action. The court explained that here, Ready Mix customers cannot buy concrete from it while avoiding being charged energy and environmental fees. On a motion for judgment on the pleadings, the court wrote that it must accept as true Sepanossian’s allegation the fees were unavoidable for customers who wished to purchase concrete from Ready Mix. View "Sepanossian v. Nat. Ready Mix Co." on Justia Law
Krasner v. Cedar Realty Trust, Inc.
Plaintiff filed a putative shareholder class action complaint in New York State Supreme Court, alleging Maryland state law claims on behalf of himself and all similarly situated preferred stockholders of Cedar Realty Trust, Inc. (“Cedar”), a New York-based corporation incorporated in Maryland, following its August 2022 merger with Wheeler Real Estate Investment Trusts, Inc. (“Wheeler”) (collectively, “Defendants”). The complaint alleged Cedar and its leadership breached fiduciary duties owed to, and a contract with, shareholders such as Plaintiff and that Wheeler both aided and abetted the breach and tortiously interfered with the relevant contract. The Defendants collectively removed the case, invoking federal jurisdiction under the Class Action Fairness Act (CAFA), but the district court remanded the case to state court after Krasner argued that an exception to CAFA jurisdiction applied to his claims. The Second Circuit dismissed Defendants’ appeal and concluded that the “securities-related” exception applies. The court explained that here, the securities created a relationship between Cedar and Plaintiff that gave rise to fiduciary duties on the part of Cedar and the potential for additional claims against those parties who aid and abet Cedar’s breach of those duties. Thus, the aiding and abetting claim—and by the same logic, the tortious interference with contract claim—“seek enforcement of a right that arises from an appropriate instrument.” As such, the securities-related exception applies, and the district court properly remanded the case to state court. View "Krasner v. Cedar Realty Trust, Inc." on Justia Law