Justia Class Action Opinion Summaries
CROOKS VS. STATE
The dispute arose after the United States constructed navigation structures in the Catahoula Basin, raising water levels and affecting property in the area. Landowners in the basin, divided into Lake Plaintiffs and Swamp Plaintiffs, brought a class action against the State of Louisiana, alleging unlawful expropriation of their land and seeking damages, a declaration of ownership, and recovery of mineral royalties. The central factual issue was how to classify the Catahoula Basin: the Lake Plaintiffs argued it was part of the Little River’s banks, entitling them to ownership, while the State argued it was a lake owned by the state.After a bench trial in the Ninth Judicial District Court, the court found in favor of the plaintiffs, recognizing the Lake and Swamp Plaintiffs as owners of the disputed lands, awarding damages for inverse condemnation, and granting attorney fees. The Louisiana Court of Appeal, Third Circuit, affirmed most of the judgment but shifted the attorney fee burden entirely to the plaintiffs’ common fund. The Louisiana Supreme Court then held that plaintiffs’ compensation claims had prescribed, reversing the damages awards but leaving the attorney fee issue unresolved. When the trial court subsequently recalculated attorney fees using the lodestar method, the appellate court increased the award by applying a fourfold multiplier, finding the initial fee too low given the case’s complexity and duration.The Supreme Court of Louisiana reviewed the attorney fee award and found that while a multiplier was warranted due to the exceptional duration, risk, and complexity of the litigation, the appellate court’s fourfold multiplier was excessive given the high hourly rate used in the lodestar calculation. The court reduced the multiplier to three, setting the attorney fee at $16,713,656.20, and affirmed the appellate court’s judgment as amended. The matter was remanded for the trial court to determine appropriate reserves and payment arrangements. View "CROOKS VS. STATE" on Justia Law
NINTH INNING INC. V. NATIONAL FOOTBALL LEAGUE, INC.
A group of DirecTV subscribers, both residential and commercial, brought a class action lawsuit alleging that the National Football League (NFL) and its member teams engaged in anticompetitive conduct. The subscribers claimed that the NFL’s interlocking agreements—including pooling telecast rights, exclusive distribution through DirecTV, and arrangements with networks—suppressed competition for out-of-market NFL games. These agreements allegedly forced subscribers to pay inflated prices for the “Sunday Ticket” package, which bundled NFL games not otherwise available in their local markets.The United States District Court for the Central District of California initially allowed the case to proceed, certifying classes and admitting expert testimony by the plaintiffs’ economists. After trial, a jury found the NFL liable on antitrust grounds and awarded substantial damages to the subscribers. However, the district court later excluded the plaintiffs’ expert testimony, finding it unreliable under Federal Rule of Evidence 702, and granted judgment as a matter of law in favor of the NFL. In the alternative, the district court conditionally ordered a new trial on damages, concluding the jury’s damages calculation was not supported by the evidence and was improperly derived.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that the district court abused its discretion by excluding the plaintiffs’ expert testimony, ruling that while experts’ methods and opinions may be impeachable, such disputes are for the jury to resolve unless the methods are fundamentally unreliable or speculative. However, the appellate court agreed that a new trial on damages was warranted because the jury’s award was based on an improper calculation method. The Ninth Circuit reversed the district court’s judgment as a matter of law, affirmed the order granting a new trial on damages, remanded with instructions to reinstate the jury’s liability verdict, and directed a new trial limited to the issue of damages. View "NINTH INNING INC. V. NATIONAL FOOTBALL LEAGUE, INC." on Justia Law
Dufour v. BP Exploration & Production
The plaintiff worked as a cleanup worker in Pascagoula, Mississippi, following the 2010 Deepwater Horizon oil spill, allegedly exposed to crude oil and chemical dispersants through inhalation and direct contact. He claimed this exposure caused a chronic worsening of his preexisting asthma. The plaintiff sued BP Exploration & Production, Inc. and BP America Production Company under the Back-End Litigation Option (BELO) of the Medical Settlement Agreement related to the Deepwater Horizon class-action litigation. The parties stipulated to venue in the United States District Court for the Southern District of Mississippi.The litigation required the plaintiff to prove that his injuries were legally caused by exposure to oil spill-related substances. He proffered two experts, Dr. Michael Freeman and Dr. Shawn French, to establish causation. BP moved to exclude their testimony and for summary judgment. The district court denied the plaintiff’s request for an evidentiary hearing, excluded the expert testimony, and granted summary judgment in favor of BP, finding that the expert evidence was insufficient to raise a genuine issue of material fact as to causation. The plaintiff timely appealed.The United States Court of Appeals for the Fifth Circuit reviewed the case. It held that toxic tort causation standards, requiring expert testimony to establish both general and specific causation, apply under maritime law for BELO claims involving non-readily observable injuries with multiple possible etiologies. The Fifth Circuit found the district court did not abuse its discretion in excluding the plaintiff’s experts, both for lack of reliability and relevance under Rule 702 and Daubert, and for deficiencies in qualifications and methodology. The district court’s grant of summary judgment was affirmed. View "Dufour v. BP Exploration & Production" on Justia Law
Bien v. Union Pacific
James Bien worked as a conductor for Union Pacific Railroad Company. In 2013, he failed two vision tests required for his job and was subsequently removed from his conductor position, receiving a work restriction that prevented him from performing duties requiring color signal recognition. After several months, he was employed by Union Pacific in a different, lower-paying role. In 2015, following a notification from the company, Bien took another vision test, which he passed. He then requested a follow-up test to potentially remove his work restriction and be reinstated as a conductor. Union Pacific denied this request, determining that his prior test failures were dispositive and that the new test had been administered in error. Bien filed a discrimination charge with the EEOC in April 2020 and later brought suit under the Americans with Disabilities Act (ADA) in January 2025.Prior to Bien's lawsuit, a class action had been filed in the District of Nebraska, Harris v. Union Pacific Railroad Company, challenging similar employment actions by Union Pacific. The initial class definition was broad, but the court later certified a narrower class. The United States District Court for the Eastern District of Texas concluded that Bien fell within the original class definition but not the certified, narrower one, reasoning that his 2015 testing and related correspondence did not constitute a “fitness-for-duty examination” under the certified class. As a result, the district court held that the statute of limitations barred Bien’s claim and dismissed his case.The United States Court of Appeals for the Fifth Circuit reviewed the dismissal de novo and reversed the district court’s decision. The Fifth Circuit held that, under American Pipe tolling, a plaintiff must be unambiguously excluded from a class definition to terminate tolling of the statute of limitations. Because Bien was not unambiguously excluded from the certified class, he was entitled to tolling, and his suit was not time-barred. The case was remanded for further proceedings. View "Bien v. Union Pacific" on Justia Law
Molina v. Triumph Residential Services, Inc.
A property management company in Los Angeles employed an individual from April 2023 to September 2024. As part of the hiring and onboarding process, the employee was required to sign an arbitration agreement that mandated all employment-related claims be resolved through binding arbitration and included a waiver of class and representative actions. The employee later filed a class action lawsuit against the employer, alleging wage-and-hour violations and unfair business practices.The employer responded by filing a motion in the Superior Court of Los Angeles County to compel arbitration of the employee's individual claims, dismiss the class claims, and stay the action. The employer made clear that the Federal Arbitration Act (FAA) did not apply and relied on California law. The employee opposed, arguing that under California Labor Code section 432.6, it is illegal for an employer to require an employee to sign an arbitration agreement as a condition of employment unless the agreement is enforceable under the FAA. The Superior Court denied the employer’s motion, finding that the arbitration agreement was required as a condition of employment, thus violating section 432.6, and that, since the FAA did not apply, the agreement was unenforceable under California law.On appeal, the Court of Appeal of the State of California, Second Appellate District, Division Four, affirmed the trial court’s order. The appellate court held that, under California law, an arbitration agreement required as a condition of employment in violation of section 432.6 is unenforceable unless it is otherwise enforceable under the FAA. Because the parties agreed the FAA did not apply and the agreement was required as a condition of employment, the employer could not enforce it. The court affirmed the denial of the motion to compel arbitration. View "Molina v. Triumph Residential Services, Inc." on Justia Law
Hilton v. Lorain
Three individuals brought suit against the City of Lorain and related entities, alleging that the city charged unlawful rates and fees for water and wastewater services. They moved to certify a class consisting of all ratepayers charged these fees by the city since May 7, 2012. The class action was brought only against the City of Lorain, not the other named defendants.The Lorain County Court of Common Pleas considered whether the plaintiffs met the seven requirements for class certification under Ohio law. The court found that the proposed class was not identifiable or unambiguously defined and that the plaintiffs had not met the “predominance and superiority” requirement under Civ.R. 23(B)(3). However, it determined that the other five requirements were satisfied. Based on the two unmet requirements, the trial court denied the motion for class certification.On appeal, the Ninth District Court of Appeals found the trial court’s analysis to be confusing and seemingly contradictory, as it could not reconcile findings that the class was not identifiable with findings that other requirements were satisfied. The appellate court held that the trial court had failed to conduct the rigorous analysis required and remanded the case for further consideration of the class certification motion.The Supreme Court of Ohio reviewed the case and held that a trial court properly conducts a rigorous analysis of a class certification motion when it addresses each of the seven requirements, even if one or more are not met. The Supreme Court concluded that the trial court’s approach did not render its analysis insufficient or contradictory. Accordingly, the Supreme Court of Ohio reversed the judgment of the Ninth District Court of Appeals and remanded the case to that court to consider the remaining assignments of error. View "Hilton v. Lorain" on Justia Law
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Class Action, Supreme Court of Ohio
Chiaro v Methodist Hospitals, Inc.
Several patients brought class action lawsuits against Indiana health care providers, alleging that their medical information was improperly shared with Facebook through the use of the Meta Pixel embedded in online patient portals. The plaintiffs asserted state law claims including breach of implied contract, unjust enrichment, and violations of the Indiana Deceptive Consumer Sales Act and Indiana Wiretapping Act. The health care providers had established these online portals to comply with federal regulations encouraging electronic health records, which offered incentive payments and imposed penalties for non-compliance.The health care providers removed the cases from Indiana state court to the United States District Court for the Southern District of Indiana, arguing that federal jurisdiction was proper under 28 U.S.C. § 1442(a)(1). They claimed they were “acting under” the Department of Health and Human Services when creating and maintaining their portals. District courts in multiple consolidated cases rejected this argument, finding that the providers did not meet the statutory requirements for removal under § 1442(a)(1). The courts concluded that while the providers were highly regulated and incentivized by federal policies, their actions did not amount to performing basic governmental tasks or operating under the direction of a federal officer.The United States Court of Appeals for the Seventh Circuit reviewed the consolidated appeals de novo. It held that compliance with federal regulations and incentives for patient portals did not constitute “acting under” a federal officer. The court found that the health care providers’ relationship to the federal government lacked the unusually close supervision and delegation required for federal officer removal. The court affirmed the district courts’ remand orders, holding that federal subject matter jurisdiction was not established under § 1442(a)(1). View "Chiaro v Methodist Hospitals, Inc." on Justia Law
McCain v. Mary Mahoney’s
A customer dined at a Mississippi restaurant specializing in local seafood, ordering premium snapper on three occasions between 2013 and 2018. The restaurant, along with its supplier and several managers, was later criminally charged for a long-running scheme to mislabel imported frozen fish as locally caught premium fish. All parties pled guilty, admitting to substituting and fraudulently selling over 29 tons of imported fish as local species during a multi-year period. The customer alleged that he paid high prices for what he believed to be premium Gulf snapper, but was instead served inferior imported fish, and he brought a class action seeking damages under federal and state law.The United States District Court for the Southern District of Mississippi dismissed the complaint under Rule 12(b)(1), finding no cognizable Article III injury. The court reasoned that since the plaintiff consumed his meals without complaint, paying for fish he would not have otherwise purchased was not a concrete injury. It also found the allegations insufficiently particularized, as the plaintiff did not specifically allege that imported fish was served on the dates he dined or that all snapper sold on those dates was misbranded. The court denied motions to amend the judgment and complaint, concluding any amendments would be futile.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo and reversed the district court’s dismissal. The Fifth Circuit held that the plaintiff plausibly suffered a concrete and particularized injury in fact under Article III, either by being fraudulently induced to purchase inferior fish or by overpaying due to fraud. The court concluded that the allegations of widespread and routine fish substitution at the restaurant plausibly affected the plaintiff’s meals, particularly his August 21, 2018, visit. The denial of leave to amend was vacated, and the case was remanded for further proceedings. View "McCain v. Mary Mahoney's" on Justia Law
CHATHAM COUNTY v. SMITH
Chatham County established a fire protection service fee, assessed either as a flat charge per parcel or based on the square footage of structures, on all real property in a special district comprising unincorporated areas of the county. Initially, fire services were provided by Chatham Emergency Services, Inc. (CES), funded by direct payments from property owners. When payment rates fell and CES could no longer provide services as before, the county contracted with CES and adopted a fire service protection tax, later replaced by the Fire Protection Service Fee Ordinance in 2022 and revised in 2023. The fee was collected from property owners in the designated area, with enforcement measures including penalties, collection costs, and potential liens.Property owners Damon L. and Sebrell E. Smith, subject to the fee, filed a class action in the Superior Court of Chatham County, seeking refunds. They contended the fee was actually an illegal tax because it was not ad valorem, as required by Georgia law. The county moved to dismiss and for summary judgment, while the plaintiffs sought class certification and summary judgment. After discovery and hearings, the superior court certified the class and granted summary judgment to the plaintiffs, holding the fire fee was a tax on real property and invalid because it was not assessed ad valorem.The Supreme Court of Georgia reviewed the case de novo. The Court agreed with the lower court that the fire protection service fee was, in substance, a tax rather than a fee or assessment. It further held that, under Georgia constitutional and statutory law, taxes on real property—including those levied in special districts—must be ad valorem. Because the county’s ordinance imposed a non-ad-valorem tax, it was unauthorized and illegal. The Supreme Court of Georgia affirmed the superior court’s judgment in favor of the property owners. View "CHATHAM COUNTY v. SMITH" on Justia Law
Phillip v. Baass
A Medi-Cal recipient resided in a nursing care facility from 2010 until her death in 2015. During her enrollment, the Department of Health Care Services paid $261,957.40 in capitation payments to her managed care plan, while the plan paid $106,672.71 to health care providers for services she actually received. The Department sought estate recovery totaling $407,774.41, which included the full amount of capitation payments, Medicare Part B premiums, and accrued interest. Her trustee and beneficiaries challenged the Department’s claim, contending that only payments for health care services actually received should be recovered.The Superior Court of San Luis Obispo County certified a class of Medi-Cal recipients and estates subject to similar estate recovery claims. After hearings on stipulated issues, the trial court determined that seeking recovery for capitation payments exceeding the actual cost of health care services received violated Welfare and Institutions Code section 14009.5 and federal law. The trial court entered judgment for the Department for the portion attributable to services actually received, and issued a declaratory judgment and writ of mandate in favor of the beneficiaries and the class, requiring the Department to reform its estate recovery practices and reprocess certain claims.The California Court of Appeal, Second Appellate District, Division Six, reviewed the case de novo. It held that Welfare and Institutions Code section 14009.5 does not permit recovery of capitation payments in excess of the amounts paid for actual health care services received. The court also ruled that the Department’s regulation permitting recovery of excess capitation is void for conflict with the statute. The judgment by the trial court was affirmed. The Department cannot recover excess capitation from estates under section 14009.5. View "Phillip v. Baass" on Justia Law