Justia Class Action Opinion Summaries

San Francisco operates a combined sewer system that collects and treats both wastewater and stormwater. In 1996, California voters approved Proposition 218, which added provisions to the California Constitution requiring voter approval for property-related charges, except for "sewer, water, and refuse collection services." Plaintiffs Robert Gluck and Adam Hertz filed a class action against the City and County of San Francisco, challenging the constitutionality of the City's sewer charges related to stormwater services. They argued that stormwater services funded by the City's sewer charges were not "sewer" services covered by the exception to Proposition 218's voter approval requirement and that the charges failed the proportionality requirement.The trial court sustained the City's demurrer without leave to amend, concluding that the City's combined sewer system provides "sewer" services falling within the voter approval exception of article XIII D, section 6(c). The court also found that the plaintiffs' fourth cause of action failed because it was based on the premise that stormwater management is not a "sewer service."The California Court of Appeal, First Appellate District, Division Three, reviewed the case. The court affirmed the trial court's judgment regarding the first three causes of action, agreeing that the City's combined sewer system provides "sewer" services exempt from the voter approval requirement. However, the court reversed the judgment regarding the fourth and fifth causes of action, concluding that the City did not establish that the plaintiffs' allegations regarding the City's reliance on wastewater factors to support charges for stormwater services were insufficient as a matter of law to establish a violation of the proportionality requirement of article XIII D, section 6(b)(3). The case was remanded for further proceedings on these claims. View "Gluck v. City and County of San Francisco" on Justia Law

Towers Watson & Co. (Towers Watson) was insured under a directors and officers (D&O) liability policy by National Union Fire Insurance Company of Pittsburgh, PA (National Union) and had excess coverage from other insurers. Following a merger with Willis Group Holdings plc (Willis), Towers Watson shareholders filed class actions alleging that the merger consideration was inadequate due to a conflict of interest involving Towers Watson’s CEO. The shareholders settled for $90 million, and Towers Watson sought indemnity coverage under the D&O policy. The insurers denied coverage, citing the policy’s “bump-up exclusion,” which excludes coverage for settlements that effectively increase the consideration paid for an acquisition.The United States District Court for the Eastern District of Virginia initially granted summary judgment in favor of Towers Watson, finding that the merger did not involve an acquisition within the meaning of the bump-up exclusion. The insurers appealed, and the United States Court of Appeals for the Fourth Circuit vacated and remanded, clarifying that the merger did involve an acquisition. On remand, the district court held that the bump-up exclusion applied, barring indemnity coverage for the settlement, and granted summary judgment in favor of the insurers.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s decision. The court held that the settlements represented an effective increase in the consideration paid for the merger, thus triggering the bump-up exclusion. The court also upheld the district court’s application of the common fund doctrine, concluding that the entire settlement amount, including the portion allocated to attorneys’ fees, fell within the exclusion. Consequently, Towers Watson was not entitled to indemnity coverage under the D&O policy. View "Towers Watson & Co. v. National Union Fire Insurance Co." on Justia Law

Edgar Osuna sued Spectrum Security Services, Inc., alleging violations of the California Labor Code. He brought five individual and class claims, and a sixth representative claim under the Labor Code Private Attorneys General Act of 2004 (PAGA). The trial court dismissed Osuna’s class claims, sent his individual claims to arbitration, and sustained Spectrum’s demurrer to his PAGA claim without leave to amend. The court concluded that Osuna lacked standing to bring the PAGA claim because he did not suffer a Labor Code violation within the one-year statute of limitations for recovering civil penalties.The trial court’s decision was based on the interpretation that Osuna needed to have suffered a violation within the one-year period before filing his PAGA notice. Osuna appealed, arguing that he is an aggrieved employee with standing to assert a representative PAGA claim because he suffered Labor Code violations during his employment with Spectrum.The California Court of Appeal, Second Appellate District, Division Six, reviewed the case. The court concluded that the trial court erred in its interpretation of the standing requirements under PAGA. The appellate court held that to have standing under PAGA, an employee must have been employed by the alleged violator and suffered at least one Labor Code violation, regardless of whether the violation occurred within the one-year statute of limitations for recovering civil penalties. The court emphasized that the statute of limitations is an affirmative defense and does not affect standing.The appellate court reversed the portion of the trial court’s order sustaining Spectrum’s demurrer to Osuna’s representative PAGA claim and remanded the case for further proceedings consistent with its opinion. View "Osuna v. Spectrum Security Services, Inc." on Justia Law

The plaintiff, Joshua Naranjo, filed a class action lawsuit against Doctors Medical Center of Modesto, Inc., alleging violations of the unfair competition law (UCL) and the Consumers Legal Remedies Act (CLRA) due to the hospital's practice of charging an undisclosed "Evaluation and Management Services Fee" (EMS Fee) to emergency room patients. Naranjo claimed that the fee was charged without prior notification or agreement, making it an unfair, deceptive, and unlawful practice.The Superior Court of Stanislaus County sustained the hospital's demurrer to each cause of action in Naranjo's first amended complaint (FAC) without leave to amend and entered a judgment of dismissal. Naranjo appealed, and the Court of Appeal initially reversed the judgment, finding that Naranjo had stated valid causes of action under the UCL and CLRA and for declaratory relief. The court also directed the trial court to consider any future motion by Naranjo to amend his FAC to state a breach of contract cause of action.The California Supreme Court granted review and subsequently transferred the case back to the Court of Appeal, directing it to reconsider the matter in light of its ruling in Capito v. San Jose Healthcare System, LP. In Capito, the Supreme Court held that hospitals do not have a duty under the UCL or CLRA to disclose EMS fees to emergency room patients prior to treatment beyond what is required by the statutory and regulatory scheme.Upon reconsideration, the Court of Appeal concluded that Naranjo's claims are barred to the extent they are based on an alleged duty to disclose EMS fees prior to treatment. However, the court found that Naranjo had stated a valid contract-based cause of action for declaratory relief and should be allowed to amend his FAC to state causes of action for breach of contract and violations of the UCL and CLRA, subject to specific parameters. The judgment of dismissal was reversed, and the case was remanded for further proceedings. View "Naranjo v. Doctors Medical Center of Modesto, Inc." on Justia Law

Plaintiffs, former employees of Vicar Operating, Inc., filed a class action lawsuit alleging that Vicar failed to provide required meal periods as mandated by California Labor Code section 512 and IWC Wage Orders Nos. 4 and 5. Plaintiffs had signed written agreements waiving their right to a meal period for shifts between five and six hours, which they could revoke at any time. They argued that these prospective waivers allowed Vicar to circumvent statutory meal break requirements.The Superior Court of Los Angeles County granted summary adjudication in favor of Vicar, determining that the prospective meal period waivers were valid under section 512 and the wage orders. The court found that the waivers were enforceable as they were revocable and there was no evidence of coercion or unconscionability. Plaintiffs appealed the decision.The California Court of Appeal, Second Appellate District, Division Seven, reviewed the case. The court examined the text of section 512 and the wage orders, as well as their legislative and administrative history. It concluded that the Legislature and IWC did not intend to prohibit prospective written waivers of meal periods for shifts between five and six hours. The court noted that the IWC had historically viewed prospective written waivers as protective for both employees and employers. The court also found that the case of Brinker Restaurant Corp. v. Superior Court did not support Plaintiffs' arguments, as it did not address the timing or circumstances under which a meal period can be waived.The Court of Appeal affirmed the trial court's judgment, holding that the prospective written waivers signed by Plaintiffs were valid and enforceable under section 512 and the applicable wage orders. View "Bradsbery v. Vicar Operating" on Justia Law

The President invoked the Alien Enemies Act (AEA) to remove Venezuelan nationals identified as members of the Tren de Aragua (TdA), a designated foreign terrorist organization. Two detainees, along with a putative class of similarly situated detainees in the Northern District of Texas, sought injunctive relief against their summary removal under the AEA. The detainees were being held in U.S. detention facilities and were notified of their imminent removal.The District Court denied the detainees' motion for a temporary restraining order (TRO) against their removal. The detainees then moved for an emergency TRO, which was not promptly addressed by the District Court. Consequently, they appealed to the Fifth Circuit, which dismissed their appeal for lack of jurisdiction and denied their motion for an injunction pending appeal, citing insufficient time given to the district court to act. The detainees also applied to the Supreme Court for a temporary injunction.The Supreme Court of the United States reviewed the case and found that the Fifth Circuit erred in dismissing the detainees' appeal for lack of jurisdiction. The Court held that the District Court's inaction had the practical effect of refusing an injunction, given the extreme urgency and high risk of irreparable harm faced by the detainees. The Supreme Court vacated the judgment of the Fifth Circuit and remanded the case for further proceedings. The Court emphasized that due process requires adequate notice and time for detainees to seek habeas relief before removal. The Government was enjoined from removing the detainees under the AEA pending further proceedings and disposition of the petition for a writ of certiorari. View "A.A.R.P. v. Trump" on Justia Law

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