Justia Class Action Opinion Summaries

Several plaintiffs brought a class action lawsuit against a city, challenging the validity of recently adopted water rates. They alleged that the city’s new rates, implemented by a resolution passed in May 2023, violated Proposition 218 by including costs for public fire service, resulting in charges exceeding the actual cost of water service. Prior to filing suit, the plaintiffs submitted claims under the Government Claims Act, which were denied. The plaintiffs sought refunds, declaratory relief, equitable relief, and a writ of mandate.After the city litigated the case for more than a year, including discovery and other pretrial activities, it moved for judgment on the pleadings, arguing that plaintiffs failed to bring a reverse validation action as required by Government Code section 53759 and Code of Civil Procedure sections 860 et seq. The San Francisco County Superior Court granted the city’s motion, holding that the validation statutes applied, were both mandatory and jurisdictional, and that plaintiffs had not complied with them in two ways: their suit was time-barred and they failed to follow proper notice procedures, including service by publication.On appeal to the California Court of Appeal, First Appellate District, Division Two, plaintiffs argued that the city had waived the validation requirements by litigating the case and that their action was timely. The appellate court reviewed the matter de novo and held that the validation statutes were mandatory and jurisdictional for challenges to water rates, and plaintiffs’ failure to comply with statutory procedures—including timely filing and notice by publication—was fatal to their claims. The court rejected arguments regarding waiver, good cause, and belated publication, ultimately affirming the trial court’s order and concluding that the procedural requirements for reverse validation actions must be strictly followed. View "Toy v. City and County of S.F." on Justia Law

A private company operating an automated license plate recognition (ALPR) system collected and stored images of license plates and related data, including date, time, and location, from vehicles in public areas in California. The company maintained a written usage and privacy policy, posted on its website, which set out authorized uses of the ALPR information and procedures for access and security. A California resident whose license plate information was collected by this system filed a class action lawsuit, alleging that the company violated the ALPR statute by failing to meaningfully implement or publicly disclose a compliant usage and privacy policy, by failing to enact adequate security measures, and by improperly allowing customers to use the data for unauthorized purposes. The plaintiff claimed harm based on an asserted invasion of privacy due to the collection and storage of his information, but did not allege any unauthorized access, disclosure, or tangible injury.The Superior Court of San Diego County granted summary judgment to the company, finding that the plaintiff lacked standing because he had not suffered actual harm as required by the ALPR statute. The court also denied another class member’s ex parte application to intervene as a substitute plaintiff, partly because the application was untimely and partly because he too failed to demonstrate actual harm resulting from a statutory violation.On appeal, the California Court of Appeal, Fourth Appellate District, Division One, affirmed both rulings. The appellate court held that standing to sue under the ALPR statute requires a showing of actual harm arising from a violation of the statute, not merely a statutory violation or a subjective sense of privacy invasion. The court concluded the plaintiff had not suffered actual harm, and therefore lacked standing. The appellate court also found no reversible error in the denial of the motion to intervene, as the movant failed to address all grounds for the trial court’s decision. View "Mata v. Digital Recognition Network, Inc." on Justia Law

A group of homeowners and their associations opposed amendments to a planned unit development in Baltimore City, actively communicating their disapproval to the Planning Commission. After the Commission approved the amendments, the developer filed suit against the homeowners and associations, seeking damages and alleging breach of contract and tortious interference. The homeowners and associations, believing the suit to be a strategic lawsuit against public participation (SLAPP), moved to dismiss under Maryland’s anti-SLAPP statute, Md. Code Ann., Cts. & Jud. Proc. § 5-807. The Circuit Court for Baltimore City found the lawsuit was a SLAPP and dismissed it, and the Appellate Court of Maryland affirmed the dismissal, citing evidence that the suit was intended to deter the homeowners from exercising their rights.Two years after the Appellate Court affirmed the SLAPP dismissal, the homeowners and associations filed a class action for malicious use of process against the developer, its law firm, and its attorney. They alleged unique injuries, including emotional distress, intimidation, diminished property values, and burdensome discovery demands. The Circuit Court for Baltimore City dismissed the suit, concluding that the plaintiffs had not pleaded the “special injury” required for malicious use of process. The Appellate Court of Maryland affirmed, holding that the alleged injuries were typical of litigation and not “special” as required by Maryland law.The Supreme Court of Maryland reviewed the case and held that the plaintiffs failed to state a claim for malicious use of process because they did not plead a special injury. The Court clarified that litigation expenses, temporary property value diminution, emotional distress, and chilling of constitutional rights are not special injuries under Maryland law. The Court also declined to adopt a rule that victims of a SLAPP inherently satisfy the special-injury requirement. Accordingly, the Supreme Court of Maryland affirmed the judgment of the Appellate Court. View "Millrace Condo. v. Shapiro Sher etc., PA" on Justia Law

Axsome Therapeutics, Inc., a biopharmaceutical company, developed AXS-07, an experimental migraine treatment. Beginning in late 2019, Axsome and its officers made public statements about AXS-07’s regulatory prospects and estimated filing dates for FDA approval, which plaintiffs allege were false and misleading because they omitted significant manufacturing and control deficiencies. Throughout 2020 and 2021, Axsome repeatedly delayed the expected FDA filing date for AXS-07. In April 2022, Axsome disclosed that the FDA had identified unresolved issues, causing its stock price to drop.After these disclosures, Axsome faced related litigation in the United States District Court for the Southern District of New York, including a securities class action and derivative lawsuits. The Securities Action was ultimately settled in 2026. The federal derivative suits were consolidated and stayed during the securities litigation. Meanwhile, in April and May 2025, plaintiffs in this Delaware action sent Section 220 books and records demands to Axsome, seeking company documents before filing suit. Axsome produced documents in September 2025, and the plaintiffs then filed this derivative lawsuit in the Court of Chancery of the State of Delaware.The Court of Chancery ruled that the plaintiffs’ claims were untimely under the doctrine of laches, applying Delaware’s three-year statute of limitations by analogy. The court held that the claims accrued by April 22, 2022, at the latest, and that neither the late and informally served Section 220 demands nor the existence of federal litigation tolled or excused the delay. The Court of Chancery concluded that the mere transmission of books and records demands did not suspend the limitations period, found no extraordinary circumstances to rebut the presumption of prejudice, and dismissed the complaint with prejudice as time-barred. View "In Re Axsome Therapeutics, Inc. Stockholder Derivative Litigation" on Justia Law

Clayton Creason worked as an engineer for Elanco US from November 2017 to November 2021. During his employment, Elanco offered a standard paid vacation benefit and an optional “vacation buy” program that allowed employees to purchase an extra week of paid leave by accepting a reduction in weekly salary. Creason participated in this program, reducing his pay by approximately $84 per week for the additional vacation week. After resigning, he filed suit under the Indiana Wage Payment Statute, claiming Elanco owed him the amount of the salary reduction, arguing the program required a written assignment of wages with notice of the right to rescind, as specified by Indiana law.The suit was initially filed in Indiana state court, with Creason seeking class certification for similarly situated employees. Elanco removed the case to the United States District Court for the Southern District of Indiana under the Class Action Fairness Act. The district court denied Creason’s belated motion to remand, finding his delay in seeking remand unreasonable after substantial progress in federal court. The court then dismissed some claims on the pleadings and granted summary judgment to Elanco on the remaining issues, concluding the vacation buy program did not constitute an assignment of wages and that Elanco’s policies concerning unused pandemic-related vacation hours did not violate Indiana law.The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that the district court acted within its discretion in denying the remand request due to Creason’s unreasonable delay. On the merits, the Seventh Circuit affirmed that the vacation buy program was not an assignment of wages under Indiana law and that Elanco was not obligated to pay out unused COVID-related vacation hours. The district court’s decision was affirmed. View "Creason v Elanco US Inc." on Justia Law

The plaintiff worked as a delivery driver for a furniture distribution company, transporting goods from California warehouses to customers. The furniture was sourced both within and outside California, including from Mexico, and arrived at the distribution centers before being delivered to customers. The plaintiff signed an independent contractor agreement with a delivery-service provider that included an arbitration clause, and subsequently filed two lawsuits against the furniture company and the delivery company: a class action alleging wage and hour violations, and a separate action under the Private Attorneys General Act (PAGA) for civil penalties.The Alameda County Superior Court reviewed the defendants’ omnibus motion to compel arbitration of all claims and to dismiss the plaintiff’s representative PAGA claims. The trial court found that, although the arbitration agreement was valid and enforceable and the defendants had not waived their right to arbitrate, the plaintiff qualified as a “transportation worker” under section 1 of the Federal Arbitration Act (FAA) and was thus exempt from FAA coverage. As a result, state law governed the enforcement of the arbitration agreement. The court ordered certain claims (reimbursement of expenses, wage statement claims, and unfair competition) to arbitration, but allowed wage claims to proceed in court under Labor Code section 229. It denied the motion to dismiss the representative PAGA claims, citing California Supreme Court precedent, and stayed both actions pending arbitration of individual claims.The Court of Appeal of the State of California, First Appellate District, Division One, reviewed these consolidated appeals. The court held that the plaintiff is a transportation worker exempt from the FAA because he played a direct and active role in the interstate movement of goods, even though his deliveries were intrastate and retail in nature. The court affirmed that the plaintiff has standing to pursue non-individual PAGA claims in court, following Adolph v. Uber Technologies, Inc. The order by the trial court was affirmed. View "Betanco v. Living Spaces Furniture, LLC" on Justia Law

A group of inmates incarcerated within Alabama’s state prison system filed a class action challenging the adequacy of mental health care provided by the Alabama Department of Corrections (ADOC). The plaintiffs, who suffer from serious mental illnesses, alleged that overcrowding, understaffing, and a series of systemic failures resulted in constitutionally deficient mental health services, contributing to a suicide rate far above the national average. Key alleged deficiencies included improper identification and classification of mental health needs, inadequate treatment plans, insufficient psychotherapy, lack of proper suicide risk management, improper use of segregation for mentally ill inmates, and the imposition of disciplinary sanctions for manifestations of mental illness.The United States District Court for the Middle District of Alabama managed the litigation in multiple phases. After a seven-week bench trial, the court found the ADOC liable under the Eighth Amendment for deliberate indifference to inmates’ serious mental health needs. The court then held extensive remedial proceedings, including further hearings and negotiations, and entered a comprehensive, system-wide remedial injunction. The court made detailed factual findings and, to comply with the Prison Litigation Reform Act (PLRA), issued particularized findings that the relief ordered was necessary, narrowly drawn, and the least intrusive means to remedy the constitutional violations. The court also adopted a monitoring plan to ensure compliance, involving external experts and a transition to internal oversight.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s liability findings and most aspects of the remedial and monitoring orders, holding that system-wide relief was appropriate given the systemic nature of the violations. However, the appellate court reversed certain remedial provisions where it found the relief exceeded what was necessary to correct the constitutional violations, particularly with respect to suicide-proofing cells and some staffing requirements, and as applied to a women’s facility where violations were not established. The case was remanded for modification in those limited respects. View "Braggs v. Commissioner, Alabama Department of Corrections" on Justia Law

Technicians employed by the defendant performed installation, maintenance, inspection, testing, repair, and replacement of fire alarms, fire sprinklers, and security system equipment under contracts with public entities in New York. These contracts varied in their language regarding the payment of prevailing wages: some disclaimed any obligation to pay prevailing wages, some were silent, and a few expressly based payment on prevailing wage rates. All contracts included a clause providing that any action against the defendant had to be brought within one year of accrual.The plaintiffs brought a proposed class action in the United States District Court for the Northern District of New York, alleging, among other claims, that they were owed prevailing wages as third-party beneficiaries of the contracts. The District Court granted the defendant’s motion for partial summary judgment, finding that the breach of contract claims were time-barred by the contractual limitation period, that the contracts did not expressly entitle plaintiffs to prevailing wages, and, in the alternative, that plaintiffs were not covered by the prevailing wage law. On appeal, the United States Court of Appeals for the Second Circuit held that plaintiffs were covered by Labor Law § 220 but certified two questions to the New York Court of Appeals regarding the implicit inclusion of prevailing wage promises in public works contracts and the enforceability of shortened contractual limitation periods.The New York Court of Appeals held that the promise to pay prevailing wages is implicit in every public works contract covered by Labor Law § 220, regardless of whether that promise appears in the contract’s text. As a result, employees may bring third-party beneficiary breach of contract claims to enforce the prevailing wage requirement. The Court further held that contractual agreements to shorten the statute of limitations for such claims are unenforceable. The Court answered the first certified question in the affirmative and the second in the negative. View "Walton v Comfort Sys. USA (Syracuse), Inc." on Justia Law

Several Michigan residents purchased expensive solar-panel systems from a company that promised substantial reductions in their electricity bills. The company’s advertising, prepared in part by entities connected to Trivest Partners, promoted significant savings and government payments, but the plaintiffs experienced little to no reduction in their bills and, in some cases, saw increases. The company, which operated in both Michigan and Florida, later went bankrupt. Alleging fraud and racketeering violations, the plaintiffs brought a civil RICO action and a Michigan Consumer Protection Act claim against Trivest Partners, its affiliates (all Florida entities), and the company founder.In the United States District Court for the Eastern District of Michigan, the two Florida-based Trivest defendants moved to dismiss for lack of personal jurisdiction, arguing that the civil RICO statute did not allow them to be sued in Michigan, as a court in Florida could exercise jurisdiction over all defendants. The district court denied the motion, holding that several practical factors—including the pending status of the case in Michigan, local counsel, and comparative convenience—favored retaining jurisdiction. The plaintiffs later added additional Trivest-related defendants, also Florida citizens, with the court again finding personal jurisdiction.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s interpretation of 18 U.S.C. § 1965(b) de novo. The appellate court held that the district court’s reasons, grounded in convenience and practical considerations, were insufficient as a matter of law to satisfy the “ends of justice require” standard under § 1965(b). The Sixth Circuit concluded that interests of convenience alone cannot justify asserting personal jurisdiction over defendants with no minimum contacts to the forum. The court reversed the district court’s order denying dismissal and vacated the order denying the Trivest defendants’ motions to compel arbitration. View "Hall v. Trivest Partners L.P." on Justia Law

A trucking company conducted background checks on a job applicant, both before and during his employment, using disclosure and authorization forms. The applicant alleged these forms did not comply with the requirements of the Fair Credit Reporting Act (FCRA), and initiated a class action on behalf of similarly situated job seekers and employees. He asserted that the company obtained background checks without proper, legally compliant disclosures and authorizations, in violation of federal law.The San Mateo County Superior Court initially certified the class for claims under the FCRA. After the Fifth District Court of Appeal decided *Limon v. Circle K Stores Inc.*, which interpreted the FCRA as requiring plaintiffs to show concrete injury for standing in California courts, the defendant moved to decertify the class, arguing the applicant had not identified any actual harm. The Superior Court agreed, finding that the applicant’s confusion and lack of awareness about the background checks did not amount to concrete injury, and decertified the class.The California Court of Appeal, First Appellate District, Division Three, reviewed the case. It held that California courts are not bound by Article III of the U.S. Constitution, which requires concrete injury in federal courts. The Court interpreted the FCRA’s language and legislative history to mean that statutory damages are available for willful violations, even absent proof of actual harm. It found that a statutory violation alone is sufficient to confer standing in California courts for FCRA claims, and that the applicant’s interest in his statutory rights was adequate. The Court of Appeal reversed the Superior Court’s order decertifying the class, holding that proof of actual injury is not required to maintain a class action under the FCRA in California state court. View "Askins v. CRST Expedited, Inc." on Justia Law