Justia Class Action Opinion Summaries

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

Andrew Sangster, on behalf of a class of flight instructors, filed suit against the University of North Dakota alleging that instructors were not paid for all hours worked. Sangster claimed the university compensated instructors only for student contact hours and excluded other work-related tasks such as scheduling, pre- and post-flight procedures, recordkeeping, and waiting at the airport. He sought damages for violations of the Fair Labor Standards Act (FLSA), North Dakota wage laws, unjust enrichment, and conversion.The District Court for Cass County reviewed the university’s motion to dismiss, which argued the court lacked jurisdiction because Sangster failed to give timely notice to the Office of Management and Budget as required by North Dakota law. Sangster admitted he had not provided this notice but contended his claims were contractual and thus exempt from the notice requirement. The district court denied the motion to dismiss with respect to the FLSA, state wage law, and unjust enrichment claims, finding them contractual in nature. The conversion claim was dismissed because Sangster conceded the notice requirement applied.The Supreme Court of the State of North Dakota subsequently reviewed the district court’s decision upon the University’s petition for a supervisory writ. The Supreme Court exercised its discretionary supervisory jurisdiction, holding that Sangster’s claims for relief under the FLSA, North Dakota wage laws, and unjust enrichment were not contractual in nature and therefore not authorized by N.D.C.C. ch. 32-12. The Supreme Court concluded that because Sangster had not complied with the statutory notice requirements for noncontractual claims, the district court lacked subject matter jurisdiction. The court granted the supervisory writ and directed the district court to dismiss Sangster’s case for lack of jurisdiction. View "UND v. Whelan" on Justia Law

Three Ohio natural-gas producers filed a class-action lawsuit in the Summit County Court of Common Pleas against East Ohio Gas Company (Dominion Energy Ohio). They alleged that Dominion Energy sold or used natural gas delivered into its pipeline system without properly compensating them, despite tariff provisions requiring reconciliation of delivered gas volumes. The plaintiffs claimed conversion, unjust enrichment, and violations of statutory provisions related to damages from criminal acts and theft. The class consisted of Ohio natural-gas producers participating in the Energy Choice Program whose wells were connected to Dominion Energy’s pipeline system.Judge Christine Croce partly granted Dominion Energy’s motion to dismiss by dismissing the conversion claim but allowed other claims to proceed. Dominion Energy appealed, but the Ninth District Court of Appeals dismissed the appeal, finding that Judge Croce’s order was not a final, appealable order. Subsequently, Dominion Energy sought a writ of prohibition in the Ninth District against Judge Croce, arguing that the Public Utilities Commission of Ohio (PUCO) has exclusive jurisdiction over the subject matter of the class-action claims. The natural-gas producers intervened in the prohibition action.The Ninth District Court of Appeals applied the test from Allstate Insurance Co. v. Cleveland Electric Illuminating Co. and concluded that PUCO has exclusive subject-matter jurisdiction over the claims because the resolution of the dispute depended on the interpretation and application of PUCO-approved tariffs and practices normally authorized by public utilities. The court granted summary judgment for Dominion Energy and issued a writ of prohibition ordering Judge Croce to cease jurisdiction over the class action and vacate her prior orders.On appeal, the Supreme Court of Ohio affirmed the Ninth District’s judgment. The court held that PUCO has exclusive jurisdiction over the claims asserted by the natural-gas producers, and the common pleas court patently and unambiguously lacks subject-matter jurisdiction over those claims. View "E. Ohio Gas Co v. Croce" on Justia Law

Milliman, Inc. operates a service that compiles consumer medical and prescription reports, which are then sold to insurers for underwriting decisions. The named plaintiff, James Healy, applied for life insurance, but Milliman provided a report to the insurer containing another person's medical records and social security number. This erroneous report flagged Healy as high risk for several serious medical conditions he did not actually have, resulting in the denial of his insurance application. Healy attempted to correct the report, but Milliman did not timely investigate or remedy the errors.Healy filed a class action in the United States District Court for the Western District of Washington, alleging that Milliman’s procedures violated the Fair Credit Reporting Act by failing to ensure maximum possible accuracy. The district court certified an “inaccuracy class” for those whose reports included mismatched social security numbers and risk flags. Milliman moved for partial summary judgment, arguing that Healy needed to show class-wide standing at this stage. The district court agreed, finding under TransUnion LLC v. Ramirez, 594 U.S. 413 (2021), that Healy had failed to present direct evidence of concrete injury on a class-wide basis, and dismissed the inaccuracy class.On interlocutory appeal, the United States Court of Appeals for the Ninth Circuit held that, following class certification in damages actions, both named and unnamed class members must present evidence of standing at summary judgment. However, the court clarified that plaintiffs may rely on either direct or circumstantial evidence, and need only show that a rational trier of fact could infer standing, not that standing is conclusively established. The panel reversed the district court’s partial summary judgment and remanded for reconsideration under the correct summary judgment standard. View "HEALY V. MILLIMAN, INC." on Justia Law

A group of patients civilly committed under Minnesota law challenged the state's sex offender treatment program, alleging inadequate treatment and unconstitutional conditions of confinement. The lawsuit was brought as a class action, initially filed pro se and later supported by counsel through the Minnesota Federal Bar Association’s Pro Se Project. During the litigation, the patients, citing indigence and the need for expert testimony, requested court-appointed experts under Federal Rule of Evidence 706. Both parties jointly nominated experts, and in 2013, they recommended a 50/50 split of expert costs. However, the court initially allocated all costs to the defendants, reserving the option to adjust later.After more than a decade of litigation, the United States District Court for the District of Minnesota ruled in favor of the state officials on all claims. The officials then sought to recover litigation costs, including expert fees, as prevailing parties under Federal Rule of Civil Procedure 54(d)(1). The district court declined to award any costs to the officials, citing the plaintiffs' indigence, good faith, public importance of the issues, vigorous litigation, difficulty and closeness of the issues, and potential chilling effect on future litigants.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision for abuse of discretion. The appellate court held that the district court failed to consider the plaintiffs’ 2013 recommendation to share expert costs and did not adequately weigh their acknowledged ability to pay half at that time. The Eighth Circuit vacated the district court’s cost judgment and remanded with instructions to award half of the expert costs to the prevailing defendants, to be assessed jointly and severally against the named plaintiffs. View "Karsjens v. Gandhi" on Justia Law

The plaintiffs in this case are trustees who own a property in Kīhei, Maui, which they use as a vacation home for personal use. In 2021, Maui County reclassified their property as a “short-term rental” based solely on zoning, not actual use, resulting in a higher property tax rate. The plaintiffs paid the assessed taxes but did not utilize the administrative appeals process available through the Maui County Board of Review. Instead, they filed a class action in the Circuit Court of the Second Circuit, seeking a refund and alleging that the County’s collection of the higher taxes was unconstitutional, violated due process, and resulted in unjust enrichment.The Circuit Court of the Second Circuit granted the County’s motion to dismiss, finding it lacked subject matter jurisdiction. The court determined that under Hawai‘i Revised Statutes chapter 232 and Maui County Code chapter 3.48, the proper procedure for contesting real property tax assessments—including constitutional challenges—requires first appealing to the County Board of Review and, if necessary, then to the Tax Appeal Court. Because the plaintiffs bypassed these required steps and missed the statutory deadline to appeal, the court dismissed the case with prejudice.On appeal, the Supreme Court of the State of Hawai‘i affirmed the circuit court’s dismissal. The Supreme Court held that the Tax Appeal Court has exclusive jurisdiction over appeals regarding real property tax assessments, including those raising constitutional issues, and found that the plaintiffs’ claims were time-barred due to their failure to timely pursue the established administrative remedies. As a result, the Supreme Court affirmed the circuit court’s judgment dismissing the plaintiffs’ claims for lack of subject matter jurisdiction. View "Piezko v. County of Maui" on Justia Law

A group of 169 individuals who worked at the Clark County Government Center in Las Vegas brought claims alleging that they suffered serious injuries due to exposure to toxic chemicals, including polychlorinated biphenyls (PCBs), at their workplace. The site of the Government Center had previously been used as a rail yard by Union Pacific Railroad, and plaintiffs alleged that Union Pacific dumped waste, including PCBs manufactured by the former Monsanto Company, at the site. Plaintiffs asserted that Monsanto’s corporate successors inherited liability for harms caused by the production, sale, and distribution of PCBs, which allegedly caused a range of health issues for those exposed.The plaintiffs initially filed suit in Nevada state court against multiple defendants, including Union Pacific, the Las Vegas Downtown Redevelopment Agency, and Monsanto’s successors. The claims sought compensatory and punitive damages for injuries stemming from the alleged contamination. Monsanto’s successors removed the action to the United States District Court for the District of Nevada under the Class Action Fairness Act (CAFA). The plaintiffs moved to remand the case back to state court, and the District Court granted the motion, finding that the local controversy exception to CAFA applied since the alleged injuries were localized to Clark County.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s remand order de novo. The Ninth Circuit held that CAFA’s local controversy exception did not apply because the principal injuries resulting from Monsanto’s conduct were not shown to have been incurred primarily in Nevada. The court found that plaintiffs’ allegations described nationwide distribution and harm from PCBs, with no facts indicating that Nevada experienced principal or unique injuries. Therefore, the Ninth Circuit reversed the District Court’s order remanding the case and ordered the case to proceed in federal court. View "EMPLOYEES AT THE CLARK COUNTY GOVERNMENT CENTER V. MONSANTO COMPANY" on Justia Law

Two individuals worked as delivery drivers for a transportation company for over a decade, primarily out of the company’s New Jersey terminal. Their work mainly involved picking up and delivering goods in New Jersey, with occasional deliveries in neighboring states. Each driver had a contract with the company that included a forum-selection clause requiring any disputes to be litigated in Memphis, Tennessee, and a choice-of-law clause providing that Tennessee law would govern any disputes. The company is incorporated in Delaware, headquartered in Illinois, and has operations nationwide, including in Tennessee, but neither the drivers nor the company’s relevant activities were based in Tennessee.The drivers filed a putative class action in the United States District Court for the District of New Jersey, alleging that the company violated New Jersey wage laws by withholding earnings and failing to pay overtime, among other claims. The case was transferred to the United States District Court for the Western District of Tennessee pursuant to the forum-selection clause. The company then moved to dismiss the complaint, arguing that the Tennessee choice-of-law provision applied and that Tennessee law did not recognize the claims brought under New Jersey statutes. The district court agreed, upheld the choice-of-law provision, and dismissed the case.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the enforceability of the choice-of-law provision under Tennessee’s choice-of-law rules. The court held that the contractual choice-of-law clause was unenforceable because there was no material connection between Tennessee and the transactions or parties. As a result, the Sixth Circuit reversed the district court’s dismissal and remanded the case for further proceedings. The court did not reach the question of whether Tennessee law was contrary to the fundamental policies of New Jersey. View "Andujar v. Hub Group Trucking, Inc." on Justia Law

Plaintiffs filed a class action against the Department of Homeland Security and Immigration and Customs Enforcement, alleging that the agencies were arresting noncitizens without a warrant in violation of 8 U.S.C. § 1357(a)(2). After years of litigation, the parties entered into a Consent Decree in 2021, approved by the United States District Court for the Northern District of Illinois in 2022. The Decree required the agencies to issue a policy statement, train officers, and document compliance with § 1357(a)(2). It also outlined procedures for enforcement and modification if violations were alleged.Prior to the Decree’s scheduled expiration in May 2025, Plaintiffs moved to enforce its terms and to extend its duration, asserting substantial noncompliance by Defendants. While these motions were pending, a DHS official declared the Decree terminated. On October 7, 2025, the district court found Defendants had violated the Decree, extended its term by 118 days, and ordered compliance-related relief. Later, Plaintiffs sought release or alternative detention for hundreds of individuals allegedly arrested in violation of the Decree. On November 13, 2025, the district court ordered the release of 13 individuals whom both parties agreed were arrested unlawfully, and additionally ordered release or alternatives for approximately 442 “potential class members,” pending determinations of violation.The United States Court of Appeals for the Seventh Circuit reviewed Defendants’ emergency motion to stay the district court’s October 7 and November 13 orders. The Seventh Circuit denied the request to stay the extension of the Consent Decree, holding that Defendants were unlikely to succeed on the merits of their argument that the extension violated 8 U.S.C. § 1252(f)(1). However, the court granted the stay as to the November 13 release order for those arrested pursuant to I-200 warrants and for “potential class members” pending individualized determinations under the Decree. The ruling sets forth the standards for stays and clarifies the limitations of § 1252(f)(1) in the context of class-wide injunctive relief and consent decree enforcement. View "Castanon Nava v. Department of Homeland Security" on Justia Law

The plaintiff, who worked as a truck driver for the defendants for approximately nine months in 2018, brought claims alleging that the defendants failed to provide required meal and rest breaks, failed to reimburse necessary work-related expenses, and violated California’s unfair competition law. The plaintiff also filed a representative claim for civil penalties under the Labor Code Private Attorneys General Act of 2004 (PAGA), all arising from his employment as a driver.The Superior Court of Sutter County denied the plaintiff’s motion for class certification on the meal break, rest break, expense reimbursement, and unfair competition claims. In particular, the court found that the plaintiff failed to present substantial evidence of a common policy of discouraging breaks or of a community of interest among the proposed class members. The court relied on declarations from other drivers indicating they were not discouraged from taking breaks and noting variability in their experiences. The court also granted the defendants’ motion to strike the PAGA claim on manageability grounds, reasoning that adjudicating the claim would require individual testimony from 75 drivers and would be unmanageable.The California Court of Appeal, Third Appellate District, affirmed in part and reversed in part. It affirmed the denial of class certification for the rest break and expense reimbursement claims, finding insufficient evidence of commonality. However, it reversed the denial of class certification for the meal break and derivative unfair competition claims, holding that the trial court failed to apply the burden-shifting framework required by Donohue v. AMN Services, LLC when time records show missed or unrecorded meal breaks. Additionally, the appellate court reversed the order striking the PAGA claim, holding that trial courts lack inherent authority to strike PAGA claims solely based on manageability concerns, as clarified in Estrada v. Royalty Carpet Mills, Inc. The case was remanded for further proceedings, including consideration of whether the PAGA claim is preempted by federal law. View "Dieves v. Butte Sand Trucking Co." on Justia Law