Justia Class Action Opinion Summaries

A consumer brought a lawsuit against a national retail pharmacy chain after receiving electronically printed receipts that displayed the first six and last four digits of her prepaid debit card number when she added funds to her card at one of the chain’s stores. She alleged that the retailer willfully violated the Fair and Accurate Credit Transactions Act (FACTA) by printing more than the last five digits of her card number, and she claimed this exposed her to a heightened risk of identity theft and invasion of her privacy. The consumer sought to represent a nationwide class of similarly situated individuals and requested statutory damages, punitive damages, attorney fees, and costs.The case began in the Circuit Court of Lake County, Illinois, where the retailer moved to dismiss, arguing that the consumer lacked standing because she had not alleged an actual injury and was merely a “no-injury” plaintiff. The circuit court denied the motion, reasoning that a statutory violation alone was sufficient for standing under Illinois law, and subsequently granted the plaintiff’s motion for class certification, with some modifications to the class definition. The retailer petitioned for leave to appeal this certification order. The Appellate Court of Illinois affirmed the circuit court’s decision, holding that the plaintiff had standing based on the three-part test for standing under Illinois law and finding that the violation of FACTA constituted a distinct and palpable injury, fairly traceable to the retailer’s conduct, and capable of being redressed by the requested relief.On further appeal, the Supreme Court of the State of Illinois reversed both the appellate and circuit courts. The supreme court held that the plaintiff lacked standing because she failed to allege a concrete injury—her asserted risk of future identity theft was deemed too speculative. The court concluded that, without such an injury, the plaintiff could not maintain her individual or class claims under FACTA, and directed the circuit court to dismiss the case for lack of standing. View "Fausett v. Walgreen Co." on Justia Law

Residents of Jackson, Mississippi, brought a class action lawsuit alleging that the city knowingly contaminated their drinking water with lead, failed to treat the water to prevent lead leaching, and misled the public about the water’s safety. The complaint details how city officials ignored warnings about the water system’s vulnerabilities, failed to repair critical treatment equipment, switched water sources in a way that worsened contamination, and delayed notifying residents of dangerous lead levels. Plaintiffs claim they and their families suffered significant health effects, including lead poisoning and related medical and developmental issues, as a result of consuming the contaminated water.The United States District Court for the Southern District of Mississippi granted the defendants’ motion for judgment on the pleadings. The court found that the plaintiffs failed to state a substantive due process claim against the city and that the individual city officials were entitled to qualified immunity. The district court also declined to exercise supplemental jurisdiction over the state-law claims, dismissing them without prejudice.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The Fifth Circuit held that the plaintiffs plausibly alleged a violation of their Fourteenth Amendment right to bodily integrity by claiming the city affirmatively introduced toxins into the water supply, misrepresented the water’s safety, and thereby deprived residents of the ability to make informed decisions about their health. The court also formally adopted the state-created danger doctrine as a viable theory in the circuit. The court reversed the dismissal of the due process claims against the city and vacated the dismissal of the state-law claims, remanding for further proceedings. However, the court affirmed the dismissal of claims against the individual city officials on qualified immunity grounds, finding the relevant rights were not clearly established at the time. View "Sterling v. City of Jackson" on Justia Law

Several individuals, representing a class, challenged a health insurance company’s refusal to cover gender-affirming care for transgender individuals diagnosed with gender dysphoria. The company, acting as a third-party administrator for employer-sponsored, self-funded health plans, denied coverage for such treatments based on explicit plan exclusions requested by the employer sponsors. Some plaintiffs also alleged that they were denied coverage for treatments that would have been covered for other diagnoses, such as precocious puberty, but were denied solely because of the concurrent diagnosis of gender dysphoria.The United States District Court for the Western District of Washington certified the class and granted summary judgment in favor of the plaintiffs. The district court rejected the company’s arguments that it was not subject to Section 1557 of the Affordable Care Act because its third-party administrator activities were not federally funded, that it was merely following employer instructions under ERISA, and that it was shielded by the Religious Freedom Restoration Act (RFRA). The district court also found that the exclusions constituted sex-based discrimination under Section 1557.On appeal, the United States Court of Appeals for the Ninth Circuit agreed with the district court that the company is subject to Section 1557, that ERISA does not require administrators to enforce unlawful plan terms, and that RFRA does not provide a defense in this context. However, the Ninth Circuit held that the district court’s analysis of sex-based discrimination was undermined by the Supreme Court’s intervening decision in United States v. Skrmetti, which clarified the application of sex discrimination standards to exclusions for gender dysphoria treatment. The Ninth Circuit vacated the summary judgment and remanded the case for further proceedings to consider whether, under Skrmetti, the exclusions at issue may still constitute unlawful discrimination, particularly in cases involving pretext or proxy discrimination or where plaintiffs had other qualifying diagnoses. View "PRITCHARD V. BLUE CROSS BLUE SHIELD OF ILLINOIS" on Justia Law

This case involves a class action dispute over late payments of oil proceeds to royalty and working interest owners in Oklahoma. The plaintiff, an Oklahoma landowner with royalty interests in three oil wells, alleged that Sunoco, Inc. and Sunoco Partners Marketing & Terminals, L.P. failed to pay statutory interest on late payments as required by Oklahoma’s Production Revenue Standards Act (PRSA). The PRSA mandates that first purchasers of oil must pay proceeds within strict timeframes and include 12 percent interest on any late payments. The class was defined to include all owners who received late payments from Sunoco without the required interest.After Sunoco removed the case to the United States District Court for the Eastern District of Oklahoma, the court certified the class in 2019, finding common questions predominated, including whether Sunoco owed interest on untimely payments and whether a demand was required. The district court granted partial summary judgment on liability for the PRSA claim, and after a bench trial, awarded the class over $103 million in actual damages (including prejudgment interest) and $75 million in punitive damages. Sunoco appealed, challenging class certification, standing for certain class members, the calculation of prejudgment interest, and the punitive damages award. The Tenth Circuit previously remanded for clarification on damages allocation for unidentified owners, which the district court addressed.On appeal, the United States Court of Appeals for the Tenth Circuit affirmed the district court’s rulings on class certification, ascertainability, standing, and the award of actual damages including prejudgment interest. The court held that the PRSA requires automatic payment of statutory interest on late payments, and that prejudgment interest should be compounded until paid. However, the Tenth Circuit vacated the punitive damages award, holding that punitive damages are not available for breach of contract claims under Oklahoma law when the only claim proven was a PRSA violation. The case was remanded for amendment of the judgment consistent with this opinion. View "Cline v. Sunoco" on Justia Law

Plaintiffs, C&M Resources, LLC and Winter Oil, LLC, acting on behalf of a putative class of royalty owners, alleged that Extraction Oil and Gas, Inc. underpaid royalties owed under oil and natural gas production agreements. This case is the third attempt by the plaintiffs to pursue these claims, all arising from the same set of facts. In the two prior lawsuits filed in Colorado state court, the trial courts dismissed the complaints for lack of subject matter jurisdiction, finding that the plaintiffs had failed to exhaust administrative remedies before the Colorado Oil and Gas Conservation Commission, as required by statute. The plaintiffs did not appeal those dismissals.In the present case, originally filed in state court in 2019, proceedings were stayed pending the Colorado Supreme Court’s decision in Antero Resources Corp. v. Airport Land Partners, Ltd. After the stay was lifted in 2023 and discovery commenced, Extraction determined that the amount in controversy exceeded $5 million and removed the case to federal court under the Class Action Fairness Act. The plaintiffs moved to remand, arguing that removal was untimely and that Extraction had waived its right to remove by participating in state court litigation. The United States District Court for the District of Colorado denied the remand motion, finding that the removal was timely based on information obtained during discovery and that the bankruptcy proof of claim and other documents from prior cases did not trigger the removal clock.The United States Court of Appeals for the Tenth Circuit reviewed the district court’s decisions. It held that the district court properly denied remand and correctly applied collateral estoppel, precluding the plaintiffs from relitigating the exhaustion requirement. The Tenth Circuit affirmed the district court’s judgment on the pleadings in favor of Extraction, finding no error in the lower court’s rulings. View "C&M Resources v. Extraction Oil and Gas" on Justia Law

David and Bonnie Faulk, residents of Alaska, purchased over one hundred windows from Spenard Builders Supply for their custom-built home and alleged that the windows, manufactured by JELD-WEN, were defective in breach of an oral warranty. They filed a class action in Alaska state court against Spenard Builders Supply, an Alaska corporation, and JELD-WEN, a Delaware corporation, asserting state-law claims. The defendants removed the case to federal court under the Class Action Fairness Act (CAFA), which allows federal jurisdiction based on minimal diversity in class actions.After removal, the Faulks amended their complaint to remove all class action allegations and sought to remand the case to state court. The United States District Court for the District of Alaska denied their motion to remand, relying on Ninth Circuit precedent that held federal jurisdiction under CAFA is determined at the time of removal and is not affected by post-removal amendments. The district court allowed the amendment to eliminate class allegations but ultimately dismissed the second amended complaint with prejudice, finding most claims time-barred and one insufficiently pled.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the impact of the Supreme Court’s decision in Royal Canin U.S.A., Inc. v. Wullschleger, which held that federal jurisdiction depends on the operative complaint, including post-removal amendments. The Ninth Circuit concluded that, after the Faulks removed their class action allegations, the sole basis for federal jurisdiction under CAFA was eliminated, and complete diversity was lacking. The court vacated the district court’s order dismissing the complaint and remanded with instructions to remand the case to state court unless another basis for federal jurisdiction is established. View "FAULK V. JELD-WEN, INC." on Justia Law

Several employees of the City and County of San Francisco who joined the city’s retirement system at age 40 or older and later retired due to disability challenged the method used to calculate their disability retirement benefits. The city’s retirement system uses two formulas: Formula 1, which provides a higher benefit if certain thresholds are met, and Formula 2, which imputes service years until age 60 but caps the benefit at a percentage of final compensation. Plaintiffs argued that Formula 2 discriminates against employees who enter the system at age 40 or above, in violation of the California Fair Employment and Housing Act (FEHA).Initially, the San Francisco City and County Superior Court sustained the city’s demurrer, finding the plaintiffs had not timely filed an administrative charge. The California Court of Appeal reversed that decision, allowing the case to proceed. After class certification and cross-motions for summary judgment, the trial court found triable issues and held a bench trial. At trial, plaintiffs presented expert testimony based on hypothetical calculations, while the city’s expert criticized the lack of actual data analysis and highlighted factors such as breaks in service and purchased credits.The California Court of Appeal, First Appellate District, Division Four, reviewed the trial court’s post-trial decision. The appellate court affirmed the trial court’s judgment, holding that the plaintiffs failed to prove intentional age discrimination or disparate impact under FEHA. The court found substantial evidence that Formula 2 was motivated by pension status and credited years of service, not age. The plaintiffs’ evidence was insufficient because it relied on hypotheticals rather than actual data showing a disproportionate adverse effect on the protected group. The appellate court also affirmed the denial of leave to amend the complaint, finding no reversible error. The judgment in favor of the city was affirmed. View "Carroll v. City & County of S.F." on Justia Law

Bloom Energy, a company specializing in fuel-cell servers, entered into Managed Services Agreements (MSAs), which are sale-leaseback arrangements involving banks and customers. The company initially classified these MSAs as operating leases, based on its assessment that the lease terms were less than 75% of the servers’ estimated useful lives and that the servers were not “integral equipment.” This classification affected how Bloom Energy reported revenue and liabilities in its financial statements. PricewaterhouseCoopers LLP (PwC) was engaged to audit Bloom Energy’s 2016 and 2017 financial statements, which were prepared by Bloom Energy’s management, and PwC issued an audit opinion stating that the financial statements were fairly presented in accordance with generally accepted accounting principles.After Bloom Energy went public in 2018, it later restated its financial statements, reclassifying certain MSAs as capital leases following a review prompted by PwC’s identification of an accounting issue. This restatement led to a significant drop in Bloom Energy’s stock price. Plaintiffs, consisting of shareholders, filed a class action in the United States District Court for the Northern District of California against Bloom Energy, its officers, directors, underwriters, and later added PwC as a defendant. They alleged violations of § 11 of the Securities Act of 1933, claiming that PwC was liable for material misstatements in the registration statement due to its audit opinion.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s dismissal of the claims against PwC. The Ninth Circuit held that under § 11, an independent accountant is not strictly liable for information in a registration statement or financial statements merely because it certified them. PwC’s audit opinion was a statement of subjective judgment, protected as an opinion under Omnicare, Inc. v. Laborers District Council Construction Industry Pension Fund, and did not contain actionable misstatements or omissions. The court affirmed the district court’s dismissal of the claims against PwC. View "HUNT V. PRICEWATERHOUSECOOPERS LLP" on Justia Law

The plaintiff purchased products from a company’s “Sustainability Collection,” which were advertised as sustainable and environmentally friendly. She alleged that these representations were false because the products were made with virgin synthetic and non-organic materials that are harmful to the environment. The plaintiff claimed that she would not have bought the products, or would have paid less, had she known the truth. She brought a putative class action under the Missouri Merchandising Practices Act, asserting that the company’s advertising was misleading.The United States District Court for the Eastern District of Missouri first considered and dismissed the plaintiff’s initial complaint for failure to state a claim, after which she filed an amended complaint. The company again moved to dismiss, arguing that the amended complaint lacked sufficient factual support and did not plausibly allege that a reasonable consumer would be misled. The district court agreed, finding that the amended complaint failed to provide facts making the plaintiff’s claims plausible and did not meet the required pleading standards. The court dismissed the case without specifying whether the dismissal was with or without prejudice. The plaintiff then filed a post-judgment motion for reconsideration and for leave to amend, which the district court denied, citing her failure to properly request leave to amend before judgment and her delay in doing so.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed only whether the district court abused its discretion by dismissing the amended complaint with prejudice. The Eighth Circuit held that, under Federal Rule of Civil Procedure 41(b), a Rule 12(b)(6) dismissal operates as an adjudication on the merits (i.e., with prejudice) unless the order states otherwise. The court found no abuse of discretion and affirmed the district court’s judgment. View "Ellis v. Nike USA, Inc." on Justia Law

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