Justia Class Action Opinion Summaries

A class of Louisiana medical providers sued Louisiana Preferred Provider Organizations (PPOs) in Louisiana state court, alleging that the PPOs violated the Louisiana PPO Act by discounting their bills without prior notice. After receiving class certification, the Class settled with all of the Louisiana defendants except Med-Comp; CorVel (Homeland’s insured) assigned to the Class its claims against Homeland. The assignment did not initially include the bad faith claim CorVel was pursuing against Homeland in Delaware. The Delaware Supreme Court ultimately held that the claim was time-barred. CorVel then assigned all of its claims against Homeland to the Class. The Class amended its complaint against MedComp in Louisiana state court to assert the bad faith claim against Homeland.The litigation then consisted of the Class's state law PPO Act claims against one non-diverse defendant (Med-Comp) and a state law bad faith claim as an assignee against one diverse defendant (Homeland). Homeland removed the case to federal court. The district court remanded the PPO Act claims against Med-Comp to state court and dismissed the bad faith claims as barred by the Delaware judgment.The Fifth Circuit reversed in part. The district court lacked jurisdiction because a non-diverse defendant remained from the original lawsuit. Med-Comp was not improperly joined because the Class has a possibility of recovery against Med-Comp (a non-diverse defendant) on the PPO Act claims. The court remanded with instructions to remand the entire case to state court. View "Williams v. Homeland Insurance Co. of New York" on Justia Law

The Supreme Court affirmed the judgment of the trial court granting a motion for class certification filed after a summary judgment motion had been granted in favor of the plaintiff in this case, Plantation Building of Wilmington, Inc., holding that no reversible error occurred.The defendant, the Town of Leland, consented to and joined a motion for continuance filed by Plaintiff. The trial court granted the motion. Thereafter, the trial court granted Plaintiff's motion for summary judgment and denied Defendant's competing motion. Thereafter, Plaintiff filed a motion for class certification. The trial court granted the motion. The Supreme Court affirmed, holding that because the motion for continuance identified that the issue of class certification would be resolved after addressing the cross-motions for summary judgment and the parties did not follow the sequence, Defendant waived any objection it may have had to the court granting Plaintiff's motion for class certification after granting Plaintiff's summary judgment motion. View "Plantation Building of Wilmington, Inc. v. Town of Leland" on Justia Law

Isabel Garibay appealed a trial court's confirmation of a class action settlement reached between Josue Uribe and Crown Building Maintenance Company (Crown). Uribe sued Crown as an individual regarding alleged Labor Code violations for failure to reimburse him for the cost of uniform cleaning and required footwear as a day porter doing janitorial-type work. Uribe’s suit also included a cause of action in a representative capacity for civil penalties and injunctive relief under the Labor Code Private Attorneys General Act of 2004 (PAGA). The parties reached a settlement conditioned on Uribe filing an amended complaint converting his lawsuit into a class action on his Labor Code claims and including unreimbursed employee cell phone usage costs as an additional basis for both his Labor Code and PAGA causes of action. Garibay, an unnamed member of the class once it was formed, had earlier filed in the Alameda County Superior Court a putative class action asserting Labor Code claims for unreimbursed cell phone use by Crown employees, together with a representative PAGA cause of action on that basis. When Uribe and Crown sought preliminary approval of their agreement to settle Uribe’s lawsuit on a class-wide basis, the trial court authorized Garibay to intervene as a named party in the lawsuit to oppose the settlement. The trial court later granted Uribe’s motion for preliminary approval of the settlement, and then Crown and Uribe’s joint motion for final approval. Meanwhile, the Judicial Council had referred Crown’s petition to coordinate Uribe’s and Garibay’s lawsuits to the presiding judge of the Alameda court to appoint a judge to hear the petition; that appointment remained pending at the time the judgment in Orange County was entered. After the parties advised the Alameda court no stay had been entered in the coordination proceedings, the court subsequently entered judgment. Garibay challenged the settlement after the trial court declined to rule on both Crown’s motion to dismiss Garibay’s complaint in intervention and Garibay’s motion to vacate the judgment. The Court of Appeal found Uribe's PAGA notice did not encompass a claim for unreimbursed cell phone expenses, making the notice was inadequate to support Uribe’s PAGA cause of action on that theory in his lawsuit. And because Uribe and Crown’s agreement did not allow for severance of nonviable settlement terms, judicial approval of a settlement that included Uribe’s PAGA cause of action could not survive review. The Court therefore reversed the judgment. View "Uribe v. Crown Building Maintenance Co." on Justia Law

The First Circuit affirmed the rulings of the district court denying the Commission of the New Hampshire Department of Health and Human Services' motion to dismiss Plaintiffs' complaints against her, holding that Plaintiffs' allegations of error were without merit.Plaintiffs were (1) a class of individuals who claimed to have been held against their will without due process on the basis of a certification of their need for emergency mental health treatment, and (2) a group of hospitals who claimed to have been forced to retain persons certified to be in need of such treatment. The Commissioner moved to dismiss the claims based on Eleventh Amendment immunity and Plaintiffs' asserted lack of standing. The district court denied the motion to dismiss. The First Circuit affirmed, holding that there was no merit to the Commissioner's challenges to the district court's standing and Eleventh Amendment immunity rulings. View "Doe v. Shibinette" on Justia Law

A putative nationwide class of current and former members sued MEF, a membership-based spa-services company, alleging that MEF increased fees in violation of the membership agreement. The parties settled. In exchange for the release of all claims against MEF, class members could submit claims for “vouchers” for MEF products and services. The district court approved the settlement as “fair, reasonable, and adequate” under FRCP 23(e).The Ninth Circuit vacated. If a class action settlement is considered a “coupon” under the Class Action Fairness Act (CAFA) additional restrictions apply to the settlement approval process. The court did not defer to the district court’s determination that the MEF vouchers were not coupons but applied a three-factor test, examining whether settlement benefits require class members “to hand over more of their own money before they can take advantage of” those benefits, whether the credit was valid only for “select products or services,” and how much flexibility the credit provided. The district court also failed to adequately investigate some of the potentially problematic aspects of the relationship between attorneys’ fees and the benefits to the class, which impacted the fairness of the entire settlement, not just attorneys’ fees. The district court did not apply the appropriate enhanced scrutiny; it failed to adequately address the three warning signs of implicit collusion. View "McKinney-Drobnis v. Massage Envy Franchising, LLC" on Justia Law

Railey clocked in and out of work at the Sunset Food Mart by placing her hand on a biometric scanner. She brought a class action in state court in 2019 alleging violations of the Illinois Biometric Information Privacy Act. Two years into litigation, Sunset removed the case to federal court, alleging that Railey’s claims were completely preempted by the Labor Management Relations Act. Sunset explained the timing of the removal by pointing to an interrogatory response it received from Railey in October 2020 in which she confirmed her membership in a labor union.The district court found Sunset’s removal untimely. Citing the Class Action Fairness Act, 28 U.S.C. 1453(c)(1), the Seventh Circuit affirmed the remand to state court. A Class Action Fairness Act exception for “home-state controversies” directs that district courts “shall decline to exercise jurisdiction” over a class action in which “two-thirds or more of the members of all proposed plaintiff classes in the aggregate, and the primary defendants, are citizens of the State in which the action was originally filed,” 28 U.S.C. 1332(d)(4)(B). Railey brought a putative class action on behalf of Illinois citizens against a small Illinois grocery chain under Illinois law. Sunset missed its preemption-based removal window. View "Railey v. Sunset Food Mart, Inc." on Justia Law

Current and former mortgage loan officers claim that Citizens Bank forced them—and more than a thousand of their colleagues—to work over 40 hours a week without paying them the overtime they were due under state and federal law. They filed a collective action under the Fair Labor Standards Act (FLSA), 29 U.S.C. 207, and parallel state-law claims that they wished to pursue as a class action under FRCP 23. The district court scheduled a trial on the primary factual issue in the FLSA opt-in collective action but left unresolved whether it would certify a class for the state-law opt-out Rule 23 action.The Third Circuit stayed the trial. Citizens had a sufficient likelihood of success on its mandamus petition, and mandamus is the only relief available. By compelling the FLSA opt-in collective action trial before deciding Rule 23 class certification, the district court “created a predicament for others to unravel” and “clearly and indisputably erred.” Allowing the planned FLSA collective action trial would publicly preview the evidence common to the FLSA and state-law claims, giving potential Rule 23 class members an enormous informational advantage in any subsequent “do-over.” Citizens would suffer irreparable injury absent a stay; a stay will not substantially injure the plaintiffs. View "In re: Citizens Bank, N.A." on Justia Law

Three drivers for the rideshare company, Lyft, each filed separate representative actions against Lyft under the Private Attorneys General Act of 2004 (PAGA) (Lab. Code 2698), alleging that Lyft misclassified its California drivers as independent contractors rather than employees, thereby violating multiple provisions of the Labor Code. Following mediation in 2019, one driver, Turrieta, and Lyft reached a settlement. After Turrieta moved for court approval of the settlement, the other drivers sought to intervene and object to the settlement, arguing that Lyft had engaged in a “reverse auction” by settling with Turrieta for an unreasonably low amount and that the settlement contained other provisions that were unlawful and inconsistent with PAGA’s purpose. The trial court found that they lacked standing and approved the settlement.The court of appeal affirmed. The status of the other drivers as PAGA plaintiffs in separate actions does not confer standing to move to vacate the judgment or challenge the judgment on appeal. While they may appeal from the court’s implicit order denying them intervention, there was no error in that denial. View "Turrieta v. Lyft, Inc." on Justia Law

Plaintiff Irean Amaro filed this wage and hour class action and Private Attorneys General Act (PAGA) lawsuit against defendant Anaheim Arena Management (AAM) in 2017. At the time, there were already two existing class actions asserting the same claims: one in 2014, and the other in 2016. About a month after filing her lawsuit, Amaro and AAM reached a global settlement that covered the claims asserted in the two prior class actions. The plaintiffs from the prior actions, which included intervener Rhiannon Aller, were not involved in those settlement discussions. Aller intervened in this lawsuit and objected to the settlement. Initially, the trial court denied preliminary approval of the settlement on grounds Amaro had not given the court enough information to determine the adequacy of the settlement. Amaro then engaged in extensive informal discovery and entered into an amended settlement with AAM. The court approved the amended settlement over Aller’s objections and entered judgment per the settlement’s terms. Aller appealed, claiming the court’s approval of the settlement was erroneous for two reasons: (1) the class members’ release in the settlement was improper because it extended to claims outside the scope of Amaro’s complaint, waived class members’ (from all class actions) claims under the Fair Labor Standards Act (FLSA) without obtaining their written consent, and released PAGA claims beyond the limitations period of Amaro’s own PAGA claim; and (2) the court abused its discretion in finding the settlement was not the product of a collusive reverse auction. The Court of Appeal agreed the release was overbroad, but there was nothing inherently wrong with AAM's bypassing the other class action plaintiffs and undercutting their claims by negotiating a settlement with Amaro that extinguished the other suits. Though the Court rejected most of Aller’s arguments, it reversed the judgment and remanded with directions due to the overbreadth of the release. View "Amaro v. Anaheim Arena Management" on Justia Law

Plaintiffs, three individuals who purchased oil filters designed by K&N, seek to represent a nationwide class of all purchasers of three styles of K&N oil filters that they allege share a common defect, although most proposed class members had oil filters that never exhibited the alleged defect.The Eighth Circuit affirmed the district court's finding that plaintiffs failed to plausibly allege the amount in controversy exceeded $5 million and therefore lacked jurisdiction under the Class Action Fairness Act. The court concluded that the class members whose oil filters never failed have not sustained injury or damages and cannot assist plaintiffs in meeting the $5 million jurisdictional threshold. Therefore, without these losses to aggregate, plaintiffs do not not plausibly allege an amount in controversy in excess of $5 million. View "Penrod v. K&N Engineering, Inc." on Justia Law