Justia Class Action Opinion Summaries

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The plaintiff, Ryan S., filed a class action lawsuit against UnitedHealth Group, Inc. and its subsidiaries (collectively, “UnitedHealthcare”) under the Employee Retirement Income Security Act of 1974 (“ERISA”). He alleged that UnitedHealthcare applies a more stringent review process to benefits claims for outpatient, out-of-network mental health and substance use disorder (“MH/SUD”) treatment than to otherwise comparable medical/surgical treatment. Ryan S. asserted that by doing so, UnitedHealthcare violated the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 (“Parity Act”), breached its fiduciary duty, and violated the terms of his plan.The district court granted UnitedHealthcare’s motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) based primarily on its conclusions that Ryan S. failed to allege that his claims had been “categorically” denied and insufficiently identified analogous medical/surgical claims that he had personally submitted and UnitedHealthcare had processed more favorably.The United States Court of Appeals for the Ninth Circuit reversed in part and affirmed in part the district court’s judgment. The panel concluded that Ryan S. adequately stated a claim for a violation of the Parity Act. The panel explained that an ERISA plan can violate the Parity Act in different ways, including by applying, as Ryan S. alleged here, a more stringent internal process to MH/SUD claims than to medical/surgical claims. The panel also concluded that Ryan S. alleged a breach of fiduciary duty. However, as Ryan S. failed to identify any specific plan terms that the alleged practices would violate, the panel affirmed the dismissal of his claims based on a violation of the terms of his plan. The case was remanded for further proceedings. View "Ryan S. v. UnitedHealth Group, Inc." on Justia Law

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Yasmin Varela filed a class action lawsuit against State Farm Mutual Automobile Insurance Company (State Farm) after a car accident. Varela's insurance policy with State Farm entitled her to the "actual cash value" of her totaled car. However, she alleged that State Farm improperly adjusted the value of her car based on a "typical negotiation" deduction, which was not defined or mentioned in the policy. Varela claimed this deduction was arbitrary, did not reflect market realities, and was not authorized by Minnesota law. She sued State Farm for breach of contract, breach of the covenant of good faith and fair dealing, unjust enrichment, and violation of the Minnesota Consumer Fraud Act (MCFA).State Farm moved to dismiss the complaint, arguing that Varela's claims were subject to mandatory, binding arbitration under the Minnesota No-Fault Automobile Insurance Act (No-Fault Act). The district court granted State Farm's motion in part, agreeing that Varela's claims for breach of contract, breach of the covenant of good faith and fair dealing, and unjust enrichment fell within the No-Fault Act's mandatory arbitration provision. However, the court found that Varela's MCFA claim did not seek the type of relief addressed by the No-Fault Act and was neither time-barred nor improperly pleaded, and thus denied State Farm's motion to dismiss this claim.State Farm appealed, arguing that Varela's MCFA claim was subject to mandatory arbitration and should have been dismissed. However, the United States Court of Appeals for the Eighth Circuit dismissed the appeal for lack of jurisdiction. The court found that State Farm did not invoke the Federal Arbitration Act (FAA) in its motion to dismiss and did not file a motion to compel arbitration. The court concluded that the district court's order turned entirely on a question of state law, and the policy contained no arbitration provision for the district court to "compel." Therefore, State Farm failed to establish the court's jurisdiction over the interlocutory appeal. View "Varela v. State Farm Mutual Automobile Insurance Co." on Justia Law

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The case revolves around Lisa Stone, a tenant who signed a lease agreement that required her to provide maintenance services for which she alleges she was not compensated, in violation of Minnesota law. She initiated a class-action lawsuit against Invitation Homes, Inc., the parent company of her landlord, and THR Property Management, L.P., the manager of the leased property. Stone later amended her complaint to include various subsidiaries of Invitation Homes as defendants. Some of these subsidiaries argued that Stone lacked standing to sue them as she had not alleged that they had caused any injuries.The district court denied the subsidiaries' motion to dismiss. The subsidiaries appealed this decision to the court of appeals, which reversed the district court's decision and dismissed Stone's claims against the subsidiaries. The court of appeals reasoned that Stone lacked standing to bring her claims under the theory for standing found by the district court, and the juridical-link doctrine was improperly raised by Stone for the first time on appeal and did not apply in this case.Stone appealed to the Supreme Court of Minnesota, arguing that she has standing against the subsidiaries under the juridical-link doctrine. This doctrine posits that in a class action in which a named plaintiff has not alleged an injury caused by all defendants, a class may be certified when all defendants are linked by a conspiracy or concerted scheme that harmed the class. However, the Supreme Court affirmed the decision of the court of appeals, stating that Stone had forfeited the ability to have the merits of standing under the juridical-link doctrine determined on appeal as she failed to assert standing based on the juridical-link doctrine in the district court. View "Stone, vs. Invitation Homes, Inc." on Justia Law

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The case involves an appeal by SaniSure, Inc., against a trial court's decision not to compel arbitration in a dispute with its former employee, Jasmin Vazquez. Vazquez initially worked for SaniSure from July 2019, and as part of her employment, she signed an agreement to resort to arbitration for any disputes that might arise from her employment. She eventually terminated this employment in May 2021. She returned to work for SaniSure four months later without signing any new arbitration agreement or discussing the application of the previous arbitration agreement to her new employment.Vazquez's second employment with SaniSure ended in July 2022. Later, she filed a class-action complaint alleging that SaniSure had failed to provide accurate wage statements during her second tenure. She also signaled her intent to add a derivative action under the Labor Code Private Attorney Generals Act (PAGA). SaniSure responded by submitting a “cure letter” claiming that its wage statements now comply with the Labor Code and requested that Vazquez submit her claims to binding arbitration, which Vazquez disputed.The Court of Appeal of the State of California Second Appellate District Division Six affirmed the trial court's denial of SaniSure’s motion to compel arbitration. The court found that SaniSure failed to show that Vazquez agreed to arbitrate claims arising from her second stint of employment. The court further concluded that there was no evidence of an implied agreement to arbitrate claims arising from the second employment period, as the agreement covering Vazquez’s first employment period terminated in May 2021. View "Vazquez v. SaniSure" on Justia Law

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In this case, the United States Court of Appeals for the Seventh Circuit held that a potential class of consumers who purchased infant formula manufactured by Abbott Laboratories at a plant later found to be unsanitary lacked standing to sue for economic harm. This was due to their inability to demonstrate a concrete injury-in-fact, one of the three elements required for Article III standing. The plaintiffs argued that they suffered economic harm because they would not have paid the purchase price had they known the products were at a substantial risk of being contaminated. However, the court found that the plaintiffs' alleged injury was not particularized as they did not claim that the specific products they purchased were contaminated.The court compared the case to previous decisions, notably "In re Aqua Dots," where a universal defect in a product that rendered it valueless conferred standing, and "Wallace v. ConAgra Foods, Inc.," where the plaintiffs' risk of harm was considered mere speculation. The court found that the plaintiffs' claims were more similar to the latter case, as there was only a potential risk of contamination, not a universal defect. As such, the plaintiffs' claims were dismissed for lack of standing.This decision reaffirms that plaintiffs must demonstrate a concrete and particularized injury-in-fact to establish standing in federal court. Speculative or hypothetical injuries, or injuries that are not particularized because they do not affect the plaintiff in a personal and individual way, do not meet the threshold for standing. View "Economic Loss Plaintiffs v. Abbott Laboratories" on Justia Law

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This case involves a wage dispute between an employee and his employer. The employee, George Huerta, filed a class action against his employer, CSI Electrical Contractors, seeking payment for unpaid hours worked. The case revolved around the interpretation of the Industrial Welfare Commission's Wage Order No. 16 and the term "hours worked."The Supreme Court of California was asked by the United States Court of Appeals for the Ninth Circuit to answer three questions related to Wage Order No. 16. The first question was whether time spent waiting to exit a security gate on the employer's premises was compensable as "hours worked". The court concluded that it was, as the employer's mandated exit procedure, including vehicle inspection, signified a level of control over the employee.The second question was whether time spent driving between the security gate and employee parking lots while subject to employer-imposed rules was compensable. The court held that it could be compensable as "employer-mandated travel" if the security gate was the first location where the employee's presence was required for an employment-related reason other than accessing the worksite. However, this travel time was not considered "hours worked" as the employer's rules did not imply a requisite level of control.Lastly, the court was asked whether time spent on the employer's premises during an unpaid meal period, when workers were prohibited from leaving but not required to engage in employer-mandated activities, was compensable as "hours worked". The court held that it was, as the employer's prohibition on leaving the premises prevented the employee from engaging in personal activities. The employee could bring an action to enforce the wage order and recover unpaid wages for that time. View "Huerta v. CSI Electrical Contractors" on Justia Law

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The Supreme Court of Maryland has ruled that the term "rent" under Real Property § 8-401, as applied to residential leases, refers to the fixed, periodic payments a tenant is required to make for use or occupancy of a rented premises. This definition excludes additional charges such as late fees, attorney’s fees, and court costs. The court also ruled that any provision in a residential lease that allows a landlord to allocate payments of "rent" to other obligations, thereby subjecting a tenant to eviction proceedings based on failure to pay "rent", violates Real Property § 8-208(d)(2). Further, penalties for late payment of rent, capped at 5% of the monthly amount of rent due, are inclusive of any costs of collection other than court-awarded costs. Finally, the court ruled that the Circuit Court erred in declining to review the merits of the tenants’ second renewed motion for class certification. The case has been remanded for further proceedings in line with these holdings. View "Westminster Management v. Smith" on Justia Law

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The New Jersey Supreme Court evaluated a class-action lawsuit brought by shoppers at the retail clothing store Aéropostale against the store's owner and operator, SPARC Group LLC. The plaintiffs alleged that the store used "illusory discounts," offering items at a discounted rate from an original price that was never actually charged. They claimed this practice violated the Consumer Fraud Act (CFA), the Truth in Consumer-Contract, Warranty and Notice Act (TCCWNA), and various common law contract rights.The trial court dismissed the lawsuit, finding that the plaintiffs had not demonstrated an "ascertainable loss," which is a prerequisite for a private cause of action under the CFA. The Appellate Division reversed this decision, contending that the plaintiffs had suffered an ascertainable loss because they received no value for the offered discount.The Supreme Court disagreed with the Appellate Division, ruling that the plaintiffs had not demonstrated an ascertainable loss because they purchased non-defective, conforming goods with no measurable disparity between the product they thought they were buying and what they received. Even though the court found that the store's pricing practices were deceptive and violated the CFA, it held that the plaintiffs' CFA claim failed because they had not demonstrated either a benefit-of-the-bargain loss or an out-of-pocket loss.Since the plaintiffs did not meet the "ascertainable loss" requirement of the CFA, they were also not considered to be "aggrieved consumers" under the TCCWNA, and their common law claims failed. The court reversed the Appellate Division's decision and reinstated the trial court's order dismissing the lawsuit. View "Robey v. SPARC Group, LLC" on Justia Law

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This case revolves around a promotional flyer from a car dealership that led plaintiffs to believe they had won a major prize. Instead, they received a minor prize, leading them to file a class action lawsuit alleging deception. The trial court certified the case as a class action, but the defendants appealed. The Supreme Court of North Carolina found the trial court's certification order internally inconsistent as it used one class definition in its analysis and another when certifying the class.The plaintiffs had brought their claim on behalf of all individuals who received a contest flyer and went to the dealership to claim their prize. However, the trial court's analysis of the certification criteria was based on a narrower definition of the class, specifically those who both called the dealership's hotline and visited the dealership. This inconsistency led the Supreme Court to vacate the order and remand for further proceedings.The Supreme Court further directed the trial court to examine potential conflicts of interest within the class and assess the potential for inefficiencies that could render class certification inappropriate. It emphasized that the class members' potential recovery must exceed the costs of administering a class action for certification to be warranted. View "Surgeon v. TKO Shelby, LLC" on Justia Law

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The case involved a lawsuit against Meta Platforms, Inc. (formerly known as Facebook) by a class of advertisers who claimed that Meta misrepresented the "Potential Reach" of advertisements on its platforms. The plaintiffs alleged that Meta falsely claimed that Potential Reach was an estimate of people, when in fact, it was an estimate of accounts.The United States Court of Appeals for the Ninth Circuit affirmed the district court's order certifying one class of advertisers (the damages class) who sought compensation for fraudulent misrepresentation and concealment. The court stated that the misrepresentation was a common issue for the class and that the district court properly determined that the element of justifiable reliance was capable of classwide resolution.However, the court vacated the district court's order certifying another class of advertisers (the injunction class) who sought injunctive relief. The court asked the lower court to reconsider whether the named plaintiff, Cain Maxwell, had Article III standing to seek an injunction. The case was remanded for further proceedings. View "DZ Reserve v. Meta Platforms, Inc." on Justia Law