Justia Class Action Opinion Summaries

The plaintiff filed a class action lawsuit against the defendants, alleging various wage and hour violations. The plaintiff sought class certification, which the trial court denied. The plaintiff's individual claims and representative claims under the Private Attorney General Act (PAGA) remained pending. The plaintiff appealed the denial of class certification, arguing it was appealable under the death knell doctrine, which allows immediate appeal of orders effectively terminating class claims.The Superior Court of San Bernardino County denied the plaintiff's motion for class certification, finding issues with the numerosity of subclasses, lack of typicality, predominance of individual inquiries, manageability, and superiority of class adjudication. The court noted that the PAGA claims were not subject to class certification and remained pending. The plaintiff filed a notice of appeal, asserting the order was immediately appealable under the death knell doctrine.The Court of Appeal, Fourth Appellate District, Division One, State of California, reviewed the case. The court concluded that the death knell doctrine did not apply because the PAGA claims were still pending when the notice of appeal was filed. The plaintiff's subsequent voluntary dismissal of the PAGA claims without prejudice did not retroactively make the class certification order appealable. The court held that the order denying class certification was not immediately appealable and dismissed the appeal for lack of jurisdiction. The court emphasized that any appeal of the class certification order must await the entry of a final judgment disposing of all claims. View "Reyes v. Hi-Grade Materials Co." on Justia Law

In spring 2020, Czigany Beck, a full-time student at Manhattan College, paid tuition and a comprehensive fee for the semester. Due to the COVID-19 pandemic, the college transitioned to remote learning in March 2020, and Beck received only 46% of her education in person. Beck filed a class action lawsuit against Manhattan College, claiming breach of implied contract and unjust enrichment for not refunding a portion of her tuition and fees.The United States District Court for the Southern District of New York dismissed Beck's claims. The court found that the college's statements were not specific enough to constitute a promise for in-person classes or access to on-campus facilities. The court also ruled that the comprehensive fee was nonrefundable based on the college's terms, and thus Beck's unjust enrichment claim for fees was barred. The court granted summary judgment to Manhattan College on Beck's remaining unjust enrichment claim for tuition, concluding that the college's switch to online instruction was reasonable given the pandemic.Beck appealed to the United States Court of Appeals for the Second Circuit, arguing that the district court's judgment should be reversed based on the decision in Rynasko v. New York University. Manhattan College countered with decisions from the New York Supreme Court's Appellate Division, which supported affirming the district court's judgment. The Second Circuit identified a split between federal and state courts on New York contract-law principles and certified the question to the New York Court of Appeals: whether New York law requires a specific promise to provide exclusively in-person learning to form an implied contract between a university and its students regarding tuition payments. The Second Circuit reserved decision on Beck's appeal pending the New York Court of Appeals' response. View "Beck v. Manhattan College" on Justia Law

In 2014, Emergency Medical Care Facilities, P.C. (EMCF) filed a putative class action against BlueCross BlueShield of Tennessee, Inc. (BCBST), alleging breach of contract due to a cap on certain payments for medical services. The trial court denied class certification, and the Court of Appeals affirmed. EMCF then voluntarily nonsuited its claims. After a favorable ruling in a separate lawsuit against TennCare, EMCF refiled its case against BCBST, again seeking class certification.The trial court held that collateral estoppel precluded relitigation of class certification, but the Court of Appeals reversed, stating that the prior class certification denial was not final for collateral estoppel purposes because the case had been voluntarily nonsuited.The Supreme Court of Tennessee reviewed the case to determine whether the prior denial of class certification, affirmed on appeal, was entitled to preclusive effect. The Court held that the trial court's and appellate court's decisions denying class certification in the earlier case were final and binding for purposes of collateral estoppel. The Court reasoned that the class certification issue had been fully litigated and decided, and the decision was subject to appeal, which EMCF did not pursue further. Therefore, EMCF was precluded from relitigating the class certification issue in the refiled case.The Supreme Court of Tennessee reversed the Court of Appeals' decision and remanded the case to the trial court, reinstating the order striking the class action allegations against BCBST and VSHP. The Court emphasized that the denial of class certification, affirmed on appeal, was sufficiently final to warrant preclusive effect, preventing EMCF from seeking a do-over on class certification. View "Emergency Medical Care Facilities, P.C. v. BlueCross BlueShield of Tennessee, Inc." on Justia Law

David O’Connell filed a class action lawsuit against the United States Conference of Catholic Bishops (USCCB) for fraudulent solicitation of donations. O’Connell alleged that USCCB misled donors about the use of funds collected through the Peter’s Pence Collection, which were purportedly for emergency assistance but were instead used for investments and other purposes. O’Connell claimed that if he had known the true use of the funds, he would not have donated.The United States District Court for the District of Columbia denied USCCB’s motion to dismiss the case, which was based on the church autonomy doctrine. The District Court found that O’Connell’s claims raised a secular dispute that could be resolved using neutral principles of law, without delving into religious doctrine. The court emphasized that it would not address purely religious questions if they arose during litigation.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court dismissed USCCB’s appeal for lack of jurisdiction, stating that the collateral order doctrine did not apply. The court held that the church autonomy defense could be adequately reviewed on appeal after a final judgment, and that the denial of the motion to dismiss was not conclusive or separate from the merits of the case. The court emphasized that the church autonomy doctrine does not provide immunity from suit but serves as a defense to liability. The appeal was dismissed, and the case was remanded to the District Court for further proceedings. View "O'Connell v. United States Conference of Catholic Bishops" on Justia Law

Plaintiff filed a putative class action against the City, alleging violations of the California Public Records Act (CPRA) and the California Constitution. The City maintains a website for public records requests but the Department of Water and Power (DWP) does not provide a specific method for such requests. Plaintiff, after receiving an erroneous water bill, submitted multiple records requests through the DWP website but received no response. She later posted a complaint on social media, which led to a phone call from a customer service representative but no records were provided.The Superior Court of Los Angeles County sustained the City’s demurrer without leave to amend, concluding that the CPRA does not permit class claims and that plaintiff’s individual claim was insufficient because the City provides a method for submitting CPRA requests through its main website. The court also denied the City’s motion for sanctions, finding plaintiff’s arguments were not frivolous.The California Court of Appeal, Second Appellate District, reviewed the case. The court agreed with the trial court that the CPRA does not allow for class claims, as the statutory language and case law limit judicial relief to the individual who made the records request. However, the appellate court found that plaintiff’s individual claim was sufficient, as she alleged that she submitted a request for public records and the City failed to respond within the statutory period. The appellate court reversed the judgment and remanded with directions to enter a new order sustaining the demurrer as to the class claims and overruling the demurrer to plaintiff’s individual CPRA claim. View "Di Lauro v. City of Burbank" on Justia Law

Gerald Silver filed a putative class action against the City of Albuquerque, alleging that the City violated the Telephone Consumer Protection Act (TCPA) by making pre-recorded phone calls to invite residents to virtual town hall meetings during the COVID-19 pandemic. Silver claimed he received at least seven such calls on his cell phone. The City argued that it was not subject to the TCPA as it was not a "person" under the statute and that the calls fell under the TCPA’s emergency purposes exception.The United States District Court for the District of New Mexico granted the City’s motion to dismiss, concluding that the calls fell within the emergency purposes exception of the TCPA. The court did not address whether the City was a "person" under the TCPA. Silver appealed the decision.The United States Court of Appeals for the Tenth Circuit reviewed the case de novo and affirmed the district court’s dismissal. The Tenth Circuit held that even assuming the TCPA applies to local governments, Silver’s complaint did not state a claim upon which relief could be granted. The court found that the calls were made by a local government official, were informational, and were made necessary by the COVID-19 pandemic to inform residents about virtual town hall meetings, which were a mitigation measure in response to the pandemic. Therefore, the calls fell within the TCPA’s emergency purposes exception. The court did not need to determine whether local governments qualify as persons under the TCPA. View "Silver v. City of Albuquerque" on Justia Law

Three criminal defendants in San Francisco, on behalf of themselves and a putative class, challenged the constitutionality of the San Francisco Sheriff's Office (SFSO) Pre-Trial Electronic Monitoring program (PTEM). They specifically contested Rule 5, which requires enrollees to submit to warrantless searches, and Rule 11, which allows SFSO to share participants’ location data with other law enforcement agencies without a warrant and to retain the data. The plaintiffs were divided into two subclasses: those enrolled in the program before May 2023 ("original rules subclass") and those enrolled after May 2023 ("revised rules subclass").The United States District Court for the Northern District of California granted a preliminary injunction in favor of the plaintiffs, finding that the Program Rules likely violated their rights under the United States and California constitutions. The court enjoined the enforcement of the challenged Program Rules for both subclasses. The Sheriff appealed the injunction, particularly the prohibition on enforcing the location sharing provision.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that it had jurisdiction over the appeals and that abstention was not warranted. The court found that the plaintiffs were unlikely to succeed on their facial challenges to Rule 11’s location sharing requirement for the revised rules subclass. The court determined that the Superior Court exercises a core judicial power in imposing PTEM and that the Sheriff’s program does not create separation-of-powers issues. The court also found that the location sharing provision was reasonable under the Fourth Amendment and the California Constitution when ordered by the Superior Court following an individualized determination. The court vacated the preliminary injunction as to the revised rules subclass but affirmed it for the original rules subclass due to the lack of a clear record that location sharing was a condition of PTEM enrollment. The court also granted the Sheriff’s motion to stay the district court’s subsequent order enforcing the preliminary injunction. View "SIMON V. CITY AND COUNTY OF SAN FRANCISCO" on Justia Law

Plaintiffs, former employees of Vicar Operating, Inc., filed a class action lawsuit alleging that Vicar failed to provide the required meal periods as mandated by California Labor Code section 512 and IWC Wage Orders Nos. 4-2001 and 5-2001. Vicar contended that the plaintiffs had signed valid written agreements prospectively waiving their meal periods for shifts between five and six hours, which could be revoked at any time. The plaintiffs argued that such prospective waivers allowed employers to circumvent statutory meal break requirements and denied employees a meaningful opportunity to exercise their right to meal breaks.The Superior Court of Los Angeles County granted summary adjudication in favor of Vicar, determining that the prospective waivers were valid under section 512 and the wage orders. The court found that the plain language of the statute and wage orders permitted such waivers and distinguished the case from Brinker Restaurant Corp. v. Superior Court, which did not address the timing of meal break waivers. The court also concluded that a DLSE opinion letter cited by the plaintiffs was not applicable as it interpreted different wage order regulations.The California Court of Appeal, Second Appellate District, Division Seven, reviewed the case and affirmed the lower court's decision. The appellate court held that the revocable, prospective waivers signed by the plaintiffs were enforceable in the absence of any evidence that the waivers were unconscionable or unduly coercive. The court concluded that the prospective written waiver of a 30-minute meal period for shifts between five and six hours was consistent with the text and purpose of section 512 and Wage Order Nos. 4 and 5. The court also determined that the legislative and administrative history confirmed that such waivers were consistent with the welfare of employees and that Brinker did not require a contrary result. View "Bradsbery v. Vicar Operating, Inc." on Justia Law

A publicly traded company, CoreCivic, which operates private prisons, faced scrutiny after the Bureau of Prisons raised safety and security concerns about its facilities. Following a report by the Department of Justice's Inspector General highlighting higher rates of violence and other issues in CoreCivic's prisons compared to federal ones, the Deputy Attorney General recommended reducing the use of private prisons. This led to a significant drop in CoreCivic's stock price and a subsequent shareholder class action lawsuit.The United States District Court for the Middle District of Tennessee, early in the litigation, issued a protective order allowing parties to designate discovery materials as "confidential." This led to many documents being filed under seal. The Nashville Banner intervened, seeking to unseal these documents, but the district court largely maintained the seals, including on 24 deposition transcripts, without providing specific reasons for the nondisclosure.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court emphasized the strong presumption of public access to judicial records and the requirement for compelling reasons to justify sealing them. The court found that the district court had not provided specific findings to support the seals and had not narrowly tailored the seals to serve any compelling reasons. The Sixth Circuit vacated the district court's order regarding the deposition transcripts and remanded the case for a prompt decision in accordance with its precedents, requiring the district court to determine if any parts of the transcripts meet the requirements for a seal within 60 days. View "Grae v. Corrections Corp. of Am." on Justia Law

Petitioners, representing a class of current and former Cornell University employees, participated in two defined-contribution retirement plans from 2010 to 2016. They sued Cornell and other plan fiduciaries in 2017, alleging that the plans engaged in prohibited transactions by paying excessive fees for recordkeeping services to Teachers Insurance and Annuity Association of America-College Retirement Equities Fund and Fidelity Investments Inc., in violation of the Employee Retirement Income Security Act of 1974 (ERISA) §1106(a)(1)(C).The District Court dismissed the prohibited-transaction claim, requiring plaintiffs to allege self-dealing or disloyal conduct. The Second Circuit affirmed the dismissal but on different grounds, holding that plaintiffs must plead that the transaction was unnecessary or involved unreasonable compensation, incorporating §1108(b)(2)(A) exemptions into §1106(a) claims.The Supreme Court of the United States reversed and remanded the case. The Court held that to state a claim under §1106(a)(1)(C), a plaintiff need only plausibly allege the elements contained in that provision itself, without addressing potential §1108 exemptions. The Court determined that §1108 sets out affirmative defenses, which must be pleaded and proved by defendants. The Court emphasized that the statutory text and structure do not impose additional pleading requirements for §1106(a)(1) claims and that the burden of proving exemptions rests on the defendants. View "Cunningham v. Cornell University" on Justia Law