Justia Class Action Opinion Summaries

A former employee initiated a class action lawsuit against her prior employer, alleging violations of various California Labor Code provisions and other employment-related statutes. After the lawsuit was filed, the employer entered into individual settlement agreements with approximately 954 current and former employees, offering cash payments in exchange for waivers of wage and hour claims. The total settlement payments exceeded $875,000. The named plaintiff did not sign such an agreement, but many potential class members did.The Superior Court of San Bernardino County partially granted the plaintiff’s motion to invalidate these individual settlement agreements, finding them voidable due to allegations of fraud and duress. The trial court ordered that a curative notice be sent to all affected employees, informing them of their right to revoke the agreements and join the class action. The court, however, declined to require that the notice include language stating that those who revoked their settlements might be required to repay the settlement amounts if the employer prevailed. The court instead indicated that settlement payments could be offset against any recovery and that the issue of repayment could be addressed later.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the trial court’s order after the employer petitioned for writ relief. The appellate court held that, under California’s rescission statutes (Civil Code sections 1689, 1691, and 1693), putative class members who rescind their individual settlement agreements may be required to repay the consideration received if the employer prevails, but actual repayment can be delayed until judgment. The court instructed the trial court to revise the curative notice to inform employees that repayment may be required at the conclusion of litigation, and clarified that the trial court retains discretion at judgment to adjust the equities between the parties. The order of the trial court was vacated for reconsideration consistent with these principles. View "The Merchant of Tennis, Inc. v. Superior Ct." on Justia Law

Several plaintiffs, including a truck driver and employees, alleged that their employers or associated companies collected their biometric data, such as fingerprints or hand geometry, without complying with the requirements of the Illinois Biometric Information Privacy Act (BIPA). Each plaintiff claimed that every instance of data collection constituted a separate violation, resulting in potentially massive statutory damages. Some claims were brought as class actions, raising the possibility of billions in liability for the defendants.In the United States District Court for the Northern District of Illinois, the district judges addressed whether a 2024 amendment to BIPA Section 20, which clarified that damages should be assessed per person rather than per scan, applied retroactively to cases pending when the amendment was enacted. The district courts determined that the amendment did not apply retroactively and certified this question for interlocutory appeal under 28 U.S.C. § 1292(b).The United States Court of Appeals for the Seventh Circuit reviewed the certified question de novo. The court considered Illinois’s established law of statutory retroactivity, which distinguishes between substantive and procedural (including remedial) changes. The Seventh Circuit held that the BIPA amendment was remedial because it addressed only the scope of available damages and did not alter the underlying substantive obligations or standards of liability. The court reasoned that, under Illinois law, remedial amendments apply to pending cases unless precluded by constitutional concerns, which were not present here.The Seventh Circuit concluded that the 2024 amendment to BIPA Section 20 applies retroactively to all pending cases. The court reversed the district courts’ rulings and remanded the cases for further proceedings consistent with its holding. View "Clay v Union Pacific Railroad Company" on Justia Law

Three nonprofit organizations filed a nationwide class action against the United States, alleging that the federal judiciary overcharged the public for access to court records through the PACER system. They claimed the government used PACER fees not only to fund the system itself but also for unrelated expenses, contrary to the statutory limits set by the E-Government Act. The plaintiffs sought refunds for allegedly excessive fees collected between 2010 and 2018.The United States District Court for the District of Columbia oversaw extensive litigation, including class certification and an interlocutory appeal. The United States Court of Appeals for the Federal Circuit previously affirmed that the district court had subject matter jurisdiction under the Little Tucker Act and that the government had used PACER fees for unauthorized expenses. After remand, the parties reached a settlement totaling $125 million. The district court approved the settlement, finding it fair, reasonable, and adequate under Rule 23 of the Federal Rules of Civil Procedure. The court also approved attorneys’ fees, administrative costs, and incentive awards to the class representatives. An objector, Eric Isaacson, challenged the district court’s jurisdiction, the fairness of the settlement, the attorneys’ fees, and the incentive awards.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the district court’s judgment. The court held that the district court properly exercised jurisdiction under the Little Tucker Act because each PACER transaction constituted a separate claim, none exceeding the $10,000 jurisdictional limit. The appellate court found no abuse of discretion in approving the class settlement, the attorneys’ fees, or the incentive awards. The court also held that incentive awards are not categorically prohibited and are permissible if reasonable, joining the majority of federal circuits on this issue. The district court’s judgment was affirmed. View "NVLSP v. US " on Justia Law

The plaintiff filed a putative class action against the Treasurer of the Commonwealth of Massachusetts, challenging the Massachusetts Disposition of Unclaimed Property Act under the Takings Clause of the Fifth Amendment. He alleged that the Act’s provisions regarding payment of interest on unclaimed property resulted in an uncompensated taking of his private property for public use. The plaintiff’s complaint included evidence that the state held property in his name, but did not explain his connection to the listed address or further describe the property. He had not filed a claim to recover the property through the statutory process.The United States District Court for the District of Massachusetts dismissed the action, finding that the plaintiff lacked standing to seek injunctive or declaratory relief since he did not demonstrate any future harm, and that the Commonwealth had not waived its Eleventh Amendment immunity. The district court also concluded that the plaintiff failed to state a plausible claim for relief under the Takings Clause, reasoning in part that the statute provides a mechanism for reclaiming the property in full and that any taking resulted from the plaintiff’s own neglect. The district court did not address the ripeness argument raised by the Treasurer.Upon review, the United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The appellate court held that if the plaintiff’s challenge was to the statutory interest rate, his claim was not ripe, as he had not yet made a claim for the property or been denied interest. Alternatively, if the claim was that a taking had already occurred when the state took possession, he lacked standing to seek prospective relief because any injury was in the past and not ongoing. The court thus affirmed the dismissal for lack of Article III jurisdiction. View "Narrigan v. Goldberg" on Justia Law

In the fall of 2025, federal immigration authorities increased enforcement activities in Chicago through “Operation Midway Blitz,” prompting protests near an Immigration and Customs Enforcement (ICE) detention center in Broadview, Illinois. Protesters and journalists alleged that federal officers from ICE, Customs and Border Protection (CBP), and the Department of Homeland Security (DHS) violated their First and Fourth Amendment rights by deploying tear gas and other chemical agents without justification. The plaintiffs described instances of excessive force and sought injunctive relief to stop such practices.The United States District Court for the Northern District of Illinois issued a temporary restraining order and later a broad preliminary injunction that applied districtwide, enjoining all federal law enforcement officers and agencies from using certain crowd control tactics. The court also certified a plaintiff class and required ongoing compliance reporting from DHS officials. The government appealed the preliminary injunction, arguing it was overbroad and infringed on separation of powers principles. The United States Court of Appeals for the Seventh Circuit stayed the injunction, citing its expansive scope and concerns over standing.Subsequently, as the enforcement operation ended and no further constitutional violations were reported, the plaintiffs moved to dismiss the case. The district court dismissed the case without prejudice and decertified the class, contrary to the plaintiffs’ request for dismissal with prejudice. On appeal, the United States Court of Appeals for the Seventh Circuit found that extraordinary circumstances warranted vacating the district court’s preliminary injunction. The Seventh Circuit held that vacatur was appropriate because the case had become moot and to prevent the now-unreviewable injunction from producing adverse legal consequences in future litigation. The court vacated the injunction and dismissed the appeal. View "Chicago Headline Club v. Noem" on Justia Law

A company operating a private detention facility in Colorado under contract with U.S. Immigration and Customs Enforcement was sued in a class action by a former detainee. The lawsuit challenged two of the company’s work policies for detainees: a sanitation policy that required unpaid cleaning under threat of punishment, and a voluntary work program offering minimal pay. Plaintiffs alleged that the sanitation policy violated federal anti-forced-labor laws and that the voluntary work program constituted unjust enrichment under Colorado law.After discovery, the United States District Court for the District of Colorado considered the company’s argument that, under the Supreme Court’s decision in Yearsley v. W. A. Ross Construction Co., it could not be held liable for conduct that the government had lawfully “authorized and directed.” The District Court concluded that the government contract did not instruct the company to adopt the specific work policies at issue and that the company had developed those policies on its own. Therefore, the court held that the Yearsley doctrine did not shield the company from liability and allowed the case to proceed to trial.The company appealed immediately, but the United States Court of Appeals for the Tenth Circuit dismissed the appeal for lack of jurisdiction, holding that a denial of Yearsley protection is not subject to interlocutory appeal under Cohen v. Beneficial Industrial Loan Corp.The Supreme Court of the United States affirmed the Tenth Circuit’s decision, holding that Yearsley provides a merits defense, not an immunity from suit. Therefore, a pretrial order denying Yearsley protection cannot be immediately appealed; any review must wait until after final judgment. The Court remanded the case for further proceedings. View "Geo Group, Inc. v. Menocal" on Justia Law

A tornado struck Tennessee, damaging two properties owned by a church that held property insurance with an insurer. The church filed a claim, and the insurer made a payment, but the church alleged that the insurer improperly calculated the amount by subtracting depreciation for non-material costs (such as labor) from the "actual cash value" (ACV) payment, leading to a lower payout. The insurance policy did not specify whether labor should be depreciated. The church then brought a putative class action, asserting similar claims under the laws of ten states, seeking class certification for policyholders who received reduced ACV payments because of the insurer’s practice.The United States District Court for the Middle District of Tennessee addressed several motions. It rejected the insurer’s argument that the church lacked Article III standing to assert claims under other states' laws, and denied the insurer’s motion for judgment on the pleadings as to Texas law. When considering class certification, the district court found the plaintiff satisfied Rule 23(a)’s requirements but limited class certification to four states (Arizona, California, Illinois, and Tennessee), citing unsettled law in the remaining six states. The court reasoned that the uncertain nature of laws in Kentucky, Ohio, Missouri, Mississippi, Texas, and Vermont would make a ten-state class action unwieldy, and thus declined to certify a class for those states.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s decisions. It held that the plaintiff had Article III standing to represent the class because the alleged injuries were substantially similar across the proposed class members. The appellate court found that the district court abused its discretion by not conducting an Erie analysis for five of the six excluded states and vacated the class-certification order in part, remanding for further proceedings. However, it affirmed the denial of class certification for Vermont due to insufficient authority on Vermont law. View "Generation Changers Church v. Church Mutual Ins. Co." on Justia Law

A devastating fire occurred in Lahaina on August 8, 2023, resulting in over one hundred deaths and widespread property and economic damage. Following the fire, individually represented plaintiffs and class action plaintiffs filed lawsuits in state and federal courts against entities including Hawaiian Electric, Kamehameha Schools, the State of Hawaiʻi, and the County of Maui. These class actions were eventually consolidated and refiled as a single case in the Circuit Court of the Second Circuit. Through court-ordered mediation, parties reached a “global settlement” in August 2024, resolving all claims for a total of $4.037 billion, with a portion allocated to a class settlement fund.Prior to the present appeal, the Circuit Court of the Second Circuit coordinated complex proceedings, including appointment of a special settlement master and consolidation of cases. The court issued an order establishing exclusive jurisdiction over subrogation claims related to the settlement. After the settlement was publicized and the Hawaiʻi Supreme Court issued its opinion in In re Maui Fire Cases, which clarified that insurers’ exclusive remedy after settlement is a statutory lien under HRS § 663-10, Subrogating Insurers moved to intervene in the class action, claiming protectable equitable subrogation rights if some class members did not file claims.The Supreme Court of the State of Hawaiʻi held that Subrogating Insurers do not possess a protectable interest that justifies intervention by right or permissive intervention in the class action settlement under Hawaiʻi Rules of Civil Procedure Rule 24. The court found that the statutory lien process under HRS § 663-10 is the exclusive remedy for insurers, and settlement extinguishes subrogation rights, even if some class members do not claim settlement funds. The court affirmed the Circuit Court’s order denying intervention. View "Burnes v. Hawaiian Electric Company, Inc." on Justia Law

In 1965, individuals filed a class action lawsuit against the public schools in St. Mary Parish, Louisiana, seeking to end segregation and secure injunctive relief. The district court granted an injunction requiring desegregation and oversight, with subsequent orders and modifications over the years as the parties and courts responded to compliance issues and changes in the law. After a period of inactivity, new representatives and counsel stepped in around 2018–2019, seeking to further modify the original injunction. The School Board responded by filing motions challenging the procedural propriety of the new plaintiffs, the court’s subject matter jurisdiction, and the ongoing validity of the injunction.The United States District Court for the Western District of Louisiana allowed the substitution of new plaintiffs, denied the Board’s motions to dismiss, and recertified the class, despite acknowledging factors that weighed against doing so. The Board did not appeal immediately but later renewed its objections, moving to dissolve the decades-old injunction and to strike or dismiss the new plaintiffs’ motions for further relief. The district court denied the Board’s motions to dismiss and to strike, and clarified that the Board could not present certain arguments under Rule 60(b)(5) at an upcoming hearing. The Board appealed these rulings.The United States Court of Appeals for the Fifth Circuit reviewed whether it had appellate jurisdiction under 28 U.S.C. § 1292(a)(1), which allows interlocutory appeals of orders granting, continuing, modifying, or refusing to dissolve injunctions. The Fifth Circuit held that the district court’s orders did not have the practical effect of continuing, modifying, or refusing to dissolve the injunction, but merely maintained the status quo pending further proceedings. As such, the appellate court determined it lacked jurisdiction to consider the appeal and dismissed it for want of appellate jurisdiction. View "Navy v. Sch Bd of St. Mary Prsh" on Justia Law

A Texas nonprofit health center, CentroMed, experienced a data breach in 2024 that exposed the personal information of its patients. Arturo Gonzalez, representing himself and others affected, filed a class action in Bexar County, Texas, alleging that CentroMed failed to adequately protect their private information. CentroMed, which receives federal funding and has occasionally been deemed a Public Health Service (PHS) employee under federal law, sought to remove the case to federal court, claiming removal was proper under 42 U.S.C. § 233 and 28 U.S.C. § 1442.After CentroMed was served, it notified the Department of Health and Human Services (HHS) and the United States Attorney, seeking confirmation that the data breach claims fell within the scope of PHS employee immunity. The United States Attorney appeared in state court within the required 15 days, ultimately informing the court that CentroMed was not deemed a PHS employee for the acts at issue because the claims did not arise from medical or related functions. Despite this, CentroMed removed the case to the United States District Court for the Western District of Texas 37 days after service. The district court granted Gonzalez’s motion to remand, concluding that removal was improper under both statutes: the Attorney General had timely appeared, precluding removal under § 233, and removal under § 1442 was untimely.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s remand. The Fifth Circuit held that CentroMed could not remove under § 233 because the Attorney General had timely appeared and made a case-specific negative determination. The court further held that removal under § 1442 was untimely, as CentroMed did not remove within 30 days of receiving the initial pleading. Thus, the remand to state court was affirmed. View "Gonzalez v. El Centro Del Barrio" on Justia Law