Justia Class Action Opinion Summaries

A train operated by Norfolk Southern carrying hazardous materials derailed near East Palestine, Ohio, in February 2023. The cleanup released toxic chemicals into the surrounding area, prompting affected residents and businesses to file suit against the railroad and other parties in federal court. These cases were consolidated into a master class action, and after extensive discovery and mediation, Norfolk Southern agreed to a $600 million settlement for the class. The district court for the Northern District of Ohio approved the settlement in September 2024. Five class members objected and appealed, but the district court required them to post an $850,000 appeal bond by January 30, 2025, to cover administrative and taxable costs. The objectors did not pay the bond or offer a lesser amount.After the bond order, the objectors filed a motion in the United States Court of Appeals for the Sixth Circuit to eliminate or reduce the bond, but did not seek a stay. The Sixth Circuit motions panel explained that, absent a separate notice of appeal, it could only address the bond on a motion to stay, which the objectors expressly disclaimed. The objectors then moved in the district court to extend the time to appeal the bond order, but did so one day after the deadline set by Federal Rule of Appellate Procedure 4(a)(5)(A). The district court denied the motion as untimely, finding it lacked jurisdiction to grant an extension.The United States Court of Appeals for the Sixth Circuit held that the deadlines for appealing and requesting extensions are jurisdictional and cannot be equitably extended. The court dismissed the objectors’ appeal of the motion to extend for lack of jurisdiction and granted the plaintiffs’ motion to dismiss the objectors’ appeals of the settlement for failure to pay the required bond. View "In re E. Palestine Train Derailment" on Justia Law

Cocoa AJ Holdings, LLC is the developer of a mixed-use condominium project in San Francisco known as GS Heritage Place, which includes both timeshare and whole residential units. Stephen Schneider owns a timeshare interest in one of the fractional units and has voting rights in the homeowners association. In 2018, Schneider filed a class action lawsuit against Cocoa and others, alleging improper management practices, including the use of fractional units as hotel rooms and misallocation of expenses. The parties settled that lawsuit in 2020, with Schneider agreeing not to disparage Cocoa or solicit further claims against it, and to cooperate constructively in future dealings.In 2022, Schneider initiated another lawsuit against Cocoa. In response, Cocoa filed a cross-complaint against Schneider, alleging intentional interference with prospective economic advantage, breach of contract (the settlement agreement), unjust enrichment, and defamation. Cocoa claimed Schneider engaged in a campaign to prevent the sale of unsold units as whole units, formed unofficial owner groups, made disparaging statements, and threatened litigation, all of which allegedly violated the prior settlement agreement and harmed Cocoa’s economic interests.Schneider moved to strike the cross-complaint under California’s anti-SLAPP statute (Code of Civil Procedure section 425.16), arguing that Cocoa’s claims arose from his protected activities—namely, petitioning the courts and speaking on matters of public interest related to association management. The Superior Court of the City and County of San Francisco granted Schneider’s motion, finding that all claims in the cross-complaint arose from protected activity and that Cocoa failed to show a probability of prevailing on the merits.The California Court of Appeal, First Appellate District, Division Three, affirmed the trial court’s order. The court held that Cocoa’s claims were based on Schneider’s protected litigation and association management activities, and that Cocoa did not establish a likelihood of success on any of its claims. View "Cocoa AJ Holdings, LLC v. Schneider" on Justia Law

After a series of chemical explosions at an industrial plant in Crosby, Texas, following Hurricane Harvey, property owners and lessees in the affected area experienced contamination and property damage. These individuals, including the appellants, initially participated in a federal class action seeking both injunctive and monetary relief for the harm caused by the explosions. The federal district court certified a class for injunctive relief but declined to certify a class for monetary damages. Subsequently, a class settlement addressed only injunctive relief, leaving monetary claims unresolved.Following the settlement, nearly 800 class members, including the appellants, filed individual lawsuits in Texas state court seeking monetary damages for their property-related claims. The appellants acknowledged that their claims accrued in September 2017 and were subject to a two-year statute of limitations, but argued that the pendency of the federal class action tolled the limitations period under Texas law. Arkema, the defendant, removed the cases to the United States District Court for the Southern District of Texas and moved to dismiss, asserting that Texas does not recognize cross-jurisdictional tolling—meaning a federal class action does not toll the state statute of limitations. The district court consolidated the cases and dismissed the claims as untimely, relying on Fifth Circuit precedent.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the dismissal de novo. The court held that, under its binding precedent, Texas law does not permit cross-jurisdictional tolling of statutes of limitations based on the pendency of a federal class action. The court rejected the appellants’ arguments for exceptions to this rule and found no intervening Texas authority to the contrary. Accordingly, the Fifth Circuit affirmed the district court’s dismissal of the appellants’ claims as time-barred. View "Ackerman v. Arkema" on Justia Law

During the COVID-19 pandemic, an employee in Nevada worked for a large retailer that required workers to undergo COVID-19 testing before each shift, following state emergency orders and workplace safety recommendations. The company did not pay employees for the time spent on these pre-shift tests. The employee filed a putative class action in the United States District Court for the District of Nevada, alleging violations of Nevada’s wage-hour statutes and the state constitution, including failure to pay for all hours worked, minimum wage, overtime, and timely payment upon termination.The United States District Court for the District of Nevada denied the employer’s motion to dismiss, which had argued that the time spent on COVID-19 testing was not compensable “work” under the federal Portal-to-Portal Act (PPA). The district court held that Nevada law had not incorporated the PPA, and thus the pre-shift screenings were compensable. The court then certified a question to the Supreme Court of Nevada, asking whether Nevada law incorporates the PPA’s exceptions to compensable work.The Supreme Court of Nevada reviewed the certified question and determined that Nevada’s wage-hour statutes do not incorporate the PPA’s broad exceptions to compensable work. The court found that Nevada law provides only narrow, specific exceptions to work compensation, unlike the PPA’s general exclusions for preliminary and postliminary activities. The court concluded that the Nevada Legislature did not intend to adopt the PPA’s exceptions, as reflected in the statutory language and legislative history. Therefore, the Supreme Court of Nevada answered the certified question in the negative, holding that Nevada’s wage-hour laws do not incorporate the PPA’s exceptions to compensable work. View "AMAZON.COM SERVS., LLC VS. MALLOY" on Justia Law

The City of Los Angeles implemented the recycLA program in 2017, establishing exclusive franchise agreements with private waste haulers to provide waste collection services for commercial and multi-unit residential properties. Under these agreements, haulers paid the City a percentage of their gross receipts as a franchise fee. Several property owners and tenants who paid for waste hauling services under this system filed a consolidated class action against the City, alleging that the franchise fees were actually an unlawful tax imposed without voter approval, in violation of Proposition 218 and related constitutional provisions. The plaintiffs sought refunds of the alleged illegal taxes and declaratory relief regarding the validity of the fees.The Superior Court of Los Angeles County considered the plaintiffs’ motion for class certification. While the court found the proposed class sufficiently numerous and ascertainable, and agreed that the question of whether the franchise fees constituted an illegal tax was subject to common proof, it identified a fundamental problem: not all proposed class members suffered an economic loss, as some landlords and property owners may have passed the cost of the fees on to tenants. The court concluded that entitlement to refunds was not susceptible to common proof and that individual issues predominated over common ones. It also found that a class action was not the superior method for resolving the dispute, due to the risk of unjust enrichment and the complexity of determining who actually bore the cost of the fees. The court denied class certification.On appeal, the California Court of Appeal, Second Appellate District, Division Four, reviewed the trial court’s order under the substantial evidence standard. The appellate court affirmed the denial of class certification, holding that the trial court did not err in finding that individual issues predominated and that class treatment was not superior. The order denying class certification was affirmed. View "Leeds v. City of L.A." on Justia Law

Two plaintiffs, each holding checking accounts with a bank, brought a class action lawsuit challenging the bank’s practices regarding overdraft fees. One plaintiff alleged that the bank breached its contract by charging multiple overdraft fees on transactions that did not initially overdraw the account but were later settled when the account was already overdrawn. The other plaintiff claimed a breach of contract when the bank charged multiple overdraft fees for repeated attempts to process a single payment that was returned for insufficient funds. Both plaintiffs sought to represent similarly situated customers.The Shawnee District Court granted the bank’s motion to dismiss, relying on a contract provision requiring customers to notify the bank of any “errors or improper charges” within 30 days of receiving their account statement. The court found this notice provision unambiguous and concluded that, because the plaintiffs did not provide timely notice, they were barred from bringing their claims. The Kansas Court of Appeals reversed, holding that the term “improper charges” in the contract was ambiguous and that the district court improperly engaged in fact-finding at the motion to dismiss stage. The appellate court determined that whether the notice provision applied was a factual question and that the ambiguity should be construed against the bank as the contract’s drafter.The Supreme Court of the State of Kansas reviewed the case and agreed with the Court of Appeals that the term “improper charges” was ambiguous. The Supreme Court went further, holding that this ambiguity must be construed against the bank, and as a matter of law, the notice provision did not apply to the overdraft fees at issue. The Supreme Court affirmed the judgment of the Court of Appeals, reversed the district court’s dismissal, and remanded the case for further proceedings. View "Harding v. Capitol Federal Savings Bank " on Justia Law

A restaurant and bar in Pennsylvania employed bartenders and servers who participated in a tip pool, which was allegedly distributed in part to a salaried manager, contrary to federal and state wage laws. An employee who worked there from September 2021 to December 2022 filed suit in the United States District Court for the Eastern District of Pennsylvania, alleging violations of the Fair Labor Standards Act (FLSA) and the Pennsylvania Minimum Wage Act (PMWA). The claims centered on the manager’s alleged receipt of tip-pool funds intended for bartenders. The plaintiff sought damages and styled the case as a hybrid action: an FLSA collective action under § 216(b) and a Rule 23(b)(3) class action for the state law claim.The parties stipulated to conditional certification of an FLSA collective, and notice was sent to potential members, ten of whom opted in. After discovery, the parties reached a settlement agreement, proposing a Rule 23(b)(3) class settlement that would release wage-and-hour claims, including unasserted FLSA claims, for all class members who did not opt out. The District Court held a hearing focused on whether class members who had not opted into the FLSA collective could be required to release FLSA claims through the class settlement. The District Court denied preliminary approval, reasoning that § 216(b) prohibited such releases, and denied reconsideration, certifying the legal question for interlocutory appeal.The United States Court of Appeals for the Third Circuit reviewed the certified question de novo. It held that § 216(b) of the FLSA establishes only the mechanism for litigating FLSA claims, not the conditions for waiving them, and does not prohibit the release of unasserted FLSA claims in a Rule 23(b)(3) opt-out class settlement. The Court vacated the District Court’s order and remanded for a full fairness inquiry under Rule 23. View "Lundeen v. 10 West Ferry Street Operations LLC" on Justia Law

A real estate investment trust that specializes in purchasing and leasing properties to cannabis companies was defrauded by one of its tenants, Kings Garden, which submitted fraudulent reimbursement requests for capital improvements. The trust paid out over $48 million based on these requests before discovering irregularities, such as forged documentation and payments for work that was not performed. After uncovering the fraud, the trust sued Kings Garden and disclosed the situation to the market, which led to a decline in its stock price.Following these events, several shareholders filed a putative class action in the United States District Court for the District of New Jersey, alleging violations of Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5. The shareholders claimed that the trust and its executives made false or misleading statements about their due diligence, tenant monitoring, and the nature of reimbursements, and that these misstatements caused their losses when the fraud was revealed. The District Court dismissed the complaint with prejudice, finding that while some statements could be misleading, the plaintiffs failed to plead facts giving rise to a strong inference of scienter, as required by the Private Securities Litigation Reform Act.On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court’s dismissal. The Third Circuit held that most of the challenged statements were either non-actionable opinions, not false or misleading, or not sufficiently specific. For the one statement plausibly alleged to be false or misleading, the court found that the facts did not support a strong inference that the statement’s maker acted with scienter. The court also rejected the application of corporate scienter and found no basis for control-person liability under Section 20(a) in the absence of a primary violation. View "Handal v. Innovative Industrial Properties Inc" on Justia Law

Nathan Gault was a party to a divorce action in the Medina County Court of Common Pleas. After the case concluded, the clerk charged him various fees, including a “Clerk Computer Operation” fee. Gault believed he had been overcharged, specifically challenging the additional dollar per page fee assessed for making a complete record of the proceedings. He filed a class-action complaint against the clerk, the county treasurer, and the county itself, alleging that the clerk charged him $125 in computer-operation fees, which was over $100 more than statutorily authorized.The Medina County Court of Common Pleas initially granted judgment on the pleadings for the defendants, finding Gault’s claim barred by res judicata. The Ninth District Court of Appeals reversed, holding that res judicata did not apply because the total amount owed and the methodology for determining the fees were not ascertainable from the final judgment in the divorce action, and the defendants were not parties to the prior proceedings. On remand, the trial court again ruled for the defendants, interpreting the statutes to permit the clerk to charge two dollars per page—one dollar under R.C. 2303.20(H) and an additional dollar under former R.C. 2303.201(B)(1). The Ninth District reversed, concluding that only one additional dollar total could be charged for the service, not one dollar per page.The Supreme Court of Ohio reviewed the case, consolidating a discretionary appeal and a certified conflict. The court held that, under the plain text of former R.C. 2303.201(B)(1), the clerk may charge only one additional dollar total for making a complete record under R.C. 2303.20(H), regardless of the number of pages. The Supreme Court of Ohio affirmed the judgment of the Ninth District Court of Appeals. View "State ex rel. Gault v. Medina Cty. Court of Common Pleas Clerk" on Justia Law

Several individuals brought a class action lawsuit against a group of insurance companies after a data breach compromised the driver’s license numbers of nearly three million people. The breach occurred when hackers exploited the companies’ online insurance quoting platform, which auto-populated sensitive information using data from both customers and third-party sources. The plaintiffs, whose information was compromised, alleged various harms, including time spent monitoring their financial records, increased risk of identity theft, emotional distress, and, for two plaintiffs, discovery of their driver’s license numbers on the dark web.The United States District Court for the Eastern District of Virginia dismissed the consolidated class action complaint, finding that none of the named plaintiffs had standing to pursue their claims. The district court concluded that the alleged injuries were either too speculative or not sufficiently concrete to satisfy Article III’s standing requirements, and granted the defendants’ motion to dismiss under Rule 12(b)(1).On appeal, the United States Court of Appeals for the Fourth Circuit reviewed whether the plaintiffs had standing to bring suit. The Fourth Circuit held that two plaintiffs, who alleged that their driver’s license numbers were actually posted on the dark web, suffered a concrete and particularized injury analogous to the common-law tort of public disclosure of private information. This injury was sufficient to confer standing to seek damages. However, the court found that the other plaintiffs, who did not allege their information was made public, lacked standing because their alleged injuries—such as increased risk of future harm, time spent on mitigation, and emotional distress—were either not imminent or not independently sufficient for standing. The Fourth Circuit therefore affirmed the district court’s dismissal as to those plaintiffs, reversed as to the two plaintiffs with information posted on the dark web, and remanded for further proceedings. View "Holmes v. Elephant Insurance Co." on Justia Law