Justia Class Action Opinion Summaries

Local Puerto Rico merchants brought unfair competition claims against major big-box retailers, alleging that during the COVID-19 pandemic, Costco Wholesale Corp. and Wal-Mart Puerto Rico, Inc. violated executive orders limiting sales to essential goods. The plaintiffs claimed that the defendants continued to sell non-essential items, capturing sales that would have otherwise gone to local retailers, and sought damages for lost sales during the 72-day period the orders were in effect.The case was initially filed as a putative class action in Puerto Rico's Court of First Instance. Costco removed the case to federal district court under the Class Action Fairness Act (CAFA). The district court denied Costco's motion to sever the claims against it and also denied the plaintiffs' motion to remand the case to state court. The district court dismissed most of the plaintiffs' claims but allowed the unfair competition claim to proceed. However, it later denied class certification and granted summary judgment for the defendants, concluding that the executive orders did not create an enforceable duty on the part of Costco and Wal-Mart.The United States Court of Appeals for the First Circuit reviewed the case on jurisdictional grounds. The court held that CAFA jurisdiction is not lost when a district court denies class certification. It also held that CAFA's "home state" exception did not apply because Costco, a non-local defendant, was a primary defendant. However, the court found that CAFA's "local controversy" exception applied because the conduct of Wal-Mart Puerto Rico, a local defendant, formed a significant basis for the claims. The court concluded that the district court did not abuse its discretion in denying Costco's motion to sever and determined that the entire case should be remanded to the Puerto Rico courts. The court reversed the district court's denial of the motion to remand, vacated the judgment on the merits for lack of jurisdiction, and instructed the district court to remand the case to the Puerto Rico courts. View "Kress Stores of Puerto Rico, Inc. v. Wal-Mart Puerto Rico, Inc." on Justia Law

A class of over 500,000 federal student loan borrowers sued the U.S. Department of Education for failing to process their borrower defense (BD) applications. The Department and the plaintiffs reached a settlement, which included automatic debt forgiveness for certain borrowers and streamlined adjudication for others. Three for-profit universities (the Schools) listed in the settlement as having substantial misconduct intervened, claiming reputational harm.The U.S. District Court for the Northern District of California approved the settlement and denied the Schools' motion to intervene as of right but allowed them to object to the settlement. The Schools appealed, arguing that the settlement caused them reputational and financial harm and interfered with their procedural rights.The United States Court of Appeals for the Ninth Circuit held that the Schools had Article III standing due to alleged reputational harm but lacked prudential standing to challenge the settlement because they did not demonstrate formal legal prejudice. The court found that the dispute between the plaintiffs and the Department was not moot, as the Department's voluntary cessation of issuing pro forma denials did not render the case moot. The court also affirmed the district court's denial of the Schools' motion to intervene as of right, concluding that the Schools did not have a significantly protectable interest and failed to show prejudice from the denial of intervention as of right.The Ninth Circuit dismissed the appeal in part and affirmed the district court's denial of intervention as of right. View "Sweet v. Everglades College, Inc." on Justia Law

In this case, the petitioners sought to disqualify a trial court judge based on alleged bias and prejudice. The key facts revolve around a wage-and-hour class action lawsuit initiated by the real parties in interest against the petitioners, their employer. During the litigation, the trial judge made comments suggesting the petitioners were attempting to evade liability through corporate restructuring. These comments were cited by the petitioners as evidence of bias.The Fresno County Superior Court judge struck the petitioners' statement of disqualification as untimely. The petitioners then sought writ review in the Court of Appeal, which held that the nonwaiver provision of section 170.3(b)(2) precluded the application of the timeliness requirement in section 170.3(c)(1) when a party alleges judicial bias or prejudice. The Court of Appeal reasoned that the nonwaiver provision should be interpreted to prohibit all forms of waiver, including implied waiver due to untimeliness.The Supreme Court of California reviewed the case and disagreed with the Court of Appeal's interpretation. The Supreme Court held that the nonwaiver provision of section 170.3(b)(2) applies only to judicial self-disqualification and does not affect the timeliness requirement for party-initiated disqualification attempts under section 170.3(c)(1). The Court emphasized that the statutory text, structure, legislative history, and case law support this interpretation. Consequently, the Supreme Court reversed the Court of Appeal's judgment and remanded the case for the lower court to determine whether the petitioners' statement of disqualification was filed in a timely manner. View "North Am. Title Co. v. Superior Court" on Justia Law

Plaintiffs, residents of Wisconsin, filed two class action complaints against Experian Information Solutions, Inc. under the Fair Credit Reporting Act (FCRA). They alleged that Experian failed to include a required statement in the "Summary of Rights" portion of their consumer reports, violating 15 U.S.C. § 1681g(c)(2)(D). Plaintiffs sought actual, statutory, and punitive damages. Experian removed the cases to federal court, where Plaintiffs moved to remand, arguing they lacked standing under Article III of the U.S. Constitution because they did not suffer a concrete harm. The federal court agreed and remanded the cases to state court.In state court, Experian moved for judgment on the pleadings, arguing Plaintiffs lacked standing under Wisconsin law and that their FCRA claim did not fall within the statute's "zone of interests." Plaintiffs contended California law should apply and that they had standing under it. The trial court, referencing the recent Limon v. Circle K Stores Inc. decision, which required a concrete injury for standing in California state courts, granted Experian's motion. Plaintiffs appealed, arguing Limon was wrongly decided.The California Court of Appeal, Fourth Appellate District, Division Three, affirmed the trial court's decision. The appellate court found Limon persuasive, holding that Plaintiffs lacked standing because they did not allege a concrete or particularized injury. The court noted that under both California and federal law, an informational injury without adverse effects is insufficient to confer standing. Consequently, the judgment in favor of Experian was affirmed. View "Muha v. Experian Information Solutions" on Justia Law

The plaintiffs, former residents of a federally subsidized housing complex, alleged that the defendants, the complex's owner and management company, failed to maintain the property in a safe and habitable condition. They claimed the defendants delayed inspections, concealed hazards, and violated housing laws. The plaintiffs sought class certification for all residents from 2004 to 2019, citing issues like a 2019 sewage backup and systemic neglect.The Superior Court in Hartford, transferred to the Complex Litigation Docket, denied the motion for class certification. The court found that the proposed class did not meet the predominance and superiority requirements under Practice Book § 9-8 (3). It reasoned that determining whether each unit was uninhabitable required individualized proof, making a class action unsuitable. The court noted that while some claims might support class certification for specific events, the broad class definition over many years was too extensive.The Connecticut Supreme Court reviewed the case and affirmed the lower court's decision. The court held that the proposed class was too broad and lacked generalized evidence for the entire period. It emphasized that the trial court had no obligation to redefine the class sua sponte. The plaintiffs did not request a narrower class definition, and the trial court was not required to do so on its own. The court concluded that the trial court did not abuse its discretion in denying class certification. View "Collier v. Adar Hartford Realty, LLC" on Justia Law

Marco Fernandez applied to rent an apartment, and RentGrow, Inc. provided a tenant screening report to the property owner. The report inaccurately indicated that Fernandez had a "possible match" with a name on the OFAC list, which includes individuals involved in serious crimes. However, the property manager did not understand or consider this information when deciding on Fernandez's application. Fernandez sued RentGrow, alleging that the company violated the Fair Credit Reporting Act (FCRA) by not ensuring the accuracy of the OFAC information.The United States District Court for the District of Maryland certified a class of individuals who had similar misleading OFAC information in their reports. The court rejected RentGrow's argument that Fernandez and the class lacked standing because they did not demonstrate a concrete injury. The district court held that the dissemination of the misleading report itself was sufficient to establish a concrete injury.The United States Court of Appeals for the Fourth Circuit reviewed the case and disagreed with the district court's conclusion. The appellate court held that reputational harm can be a concrete injury, but only if the misleading information was read and understood by a third party. In this case, there was no evidence that anyone at the property management company read or understood the OFAC information in Fernandez's report. Therefore, Fernandez failed to demonstrate a concrete injury sufficient for Article III standing. The Fourth Circuit vacated the district court's class certification order and remanded the case for further proceedings. View "Fernandez v. RentGrow, Inc." on Justia Law

Two students receiving special education services filed a class action lawsuit against the Kanawha County Board of Education, alleging that the Board denied them and other similarly situated students a free appropriate public education (FAPE) as guaranteed by the Individuals with Disabilities Education Act (IDEA). The lawsuit also claimed violations of Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act. The district court certified a class of all Kanawha County Schools students with disabilities who need behavior supports and have experienced disciplinary removals from any classroom.The United States District Court for the Southern District of West Virginia granted the plaintiffs' motion to certify the class, reasoning that the plaintiffs had presented expert evidence of disproportionate rates of suspension for students with disabilities and a detailed qualitative analysis of student records. The court found that these factors revealed a cohesive pattern indicating the absence of an effective system for developing and implementing behavioral supports for students with disabilities. The Board appealed, arguing that the certification of the plaintiff class was inconsistent with Federal Rules of Civil Procedure 23(a) and (b)(2).The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court’s certification order. The Fourth Circuit held that the certified class failed to satisfy Rule 23(a)(2)’s commonality prerequisite. The court found that the plaintiffs did not identify a common contention central to the validity of all class members’ claims. The court noted that the claims were highly diverse and individualized, involving different practices at different stages of the special education process. The absence of a common contention foreclosed class treatment. The case was remanded for further proceedings consistent with the opinion. View "G.T. v. The Board of Education of the County of Kanawha" on Justia Law

In two separate class actions, Kenneth Hasson and Jordan Schnur alleged that FullStory, Inc. and Papa John’s International, Inc. unlawfully wiretapped their online communications using FullStory’s Session Replay Code. This code intercepts detailed user interactions on websites without user consent. Hasson, a Pennsylvania resident, claimed FullStory wiretapped him while he browsed Mattress Firm’s website. Schnur, also from Pennsylvania, alleged similar wiretapping by Papa John’s website.The United States District Court for the Western District of Pennsylvania dismissed both cases for lack of personal jurisdiction. In Hasson’s case, the court found that FullStory, a Delaware corporation with its principal place of business in Georgia, did not have sufficient contacts with Pennsylvania. The court denied Hasson’s request for jurisdictional discovery. In Schnur’s case, the court ruled that Papa John’s, also a Delaware corporation with its principal place of business in Georgia, did not expressly aim its conduct at Pennsylvania, despite operating numerous restaurants in the state.The United States Court of Appeals for the Third Circuit reviewed these dismissals. The court affirmed the dismissal in Schnur’s case, agreeing that Schnur failed to show that Papa John’s expressly aimed its conduct at Pennsylvania under the Calder “effects” test. The court noted that merely operating a website accessible in Pennsylvania does not establish personal jurisdiction.However, the court vacated the dismissal in Hasson’s case and remanded it for further consideration. The court held that the District Court should have also considered whether personal jurisdiction was proper under the traditional test as articulated in Ford Motor Co. v. Montana Eighth Judicial District Court. This test examines whether the defendant purposefully availed itself of the forum and whether the plaintiff’s claims arise out of or relate to the defendant’s contacts with the forum. The court instructed the District Court to reassess FullStory’s contacts with Pennsylvania under this framework. View "Hasson v. Fullstory Inc" on Justia Law

A group of Union Pacific Railroad Company employees filed a class action lawsuit against the company, alleging that its fitness-for-duty program violated the Americans with Disabilities Act (ADA). Todd DeGeer, believing he was part of this class, filed an Equal Employment Opportunity Commission (EEOC) charge and an individual lawsuit after the class was decertified. DeGeer argued that his claims were tolled under the American Pipe & Construction Co. v. Utah doctrine. The district court dismissed his claims as untimely, finding that DeGeer was not a member of the narrowly defined class.The United States District Court for the District of Nebraska initially certified a class that included Union Pacific employees subjected to fitness-for-duty evaluations due to a reportable health event. DeGeer was on a list of employees provided by Union Pacific and submitted a declaration supporting the plaintiffs' certification motion. However, the class definition was later narrowed, and the district court certified the class under this new definition. The Eighth Circuit Court of Appeals later reversed the class certification, leading DeGeer to file his individual claims.The United States Court of Appeals for the Eighth Circuit reviewed the case and reversed the district court's decision. The Eighth Circuit held that DeGeer was entitled to American Pipe tolling because the revised class definition did not unambiguously exclude him. The court emphasized that ambiguities in class definitions should be resolved in favor of applying tolling. Consequently, DeGeer's claims were tolled during the pendency of the class action, making his individual lawsuit timely. The case was remanded for further proceedings. View "DeGeer v. Union Pacific Railroad Co." on Justia Law

The City of Los Angeles contracted with PricewaterhouseCoopers (PwC) to modernize the billing system for the Department of Water and Power (LADWP). The rollout in 2013 resulted in billing errors, leading the City to sue PwC in 2015, alleging fraudulent misrepresentation. Concurrently, a class action was filed against the City by Antwon Jones, represented by attorney Jack Landskroner, for overbilling. Discovery revealed that the City’s special counsel had orchestrated the class action to settle claims favorably for the City while planning to recover costs from PwC.The Los Angeles County Superior Court found the City engaged in extensive discovery abuse to conceal its misconduct, including withholding documents and providing false testimony. The court imposed $2.5 million in monetary sanctions against the City under the Civil Discovery Act, specifically sections 2023.010 and 2023.030, which allow sanctions for discovery misuse.The California Court of Appeal reversed the sanctions, interpreting the Civil Discovery Act as not granting general authority to impose sanctions for discovery misconduct beyond specific discovery methods. The appellate court held that sections 2023.010 and 2023.030 do not independently authorize sanctions but must be read in conjunction with other provisions of the Act.The Supreme Court of California reversed the Court of Appeal’s decision, holding that the trial court did have the authority to impose monetary sanctions under sections 2023.010 and 2023.030 for the City’s pattern of discovery abuse. The Supreme Court clarified that these sections provide general authority to sanction discovery misuse, including systemic abuses not covered by specific discovery method provisions. View "City of Los Angeles v. Pricewaterhousecoopers, LLP" on Justia Law