Justia Class Action Opinion Summaries

The plaintiff worked as a delivery driver for a furniture distribution company, transporting goods from California warehouses to customers. The furniture was sourced both within and outside California, including from Mexico, and arrived at the distribution centers before being delivered to customers. The plaintiff signed an independent contractor agreement with a delivery-service provider that included an arbitration clause, and subsequently filed two lawsuits against the furniture company and the delivery company: a class action alleging wage and hour violations, and a separate action under the Private Attorneys General Act (PAGA) for civil penalties.The Alameda County Superior Court reviewed the defendants’ omnibus motion to compel arbitration of all claims and to dismiss the plaintiff’s representative PAGA claims. The trial court found that, although the arbitration agreement was valid and enforceable and the defendants had not waived their right to arbitrate, the plaintiff qualified as a “transportation worker” under section 1 of the Federal Arbitration Act (FAA) and was thus exempt from FAA coverage. As a result, state law governed the enforcement of the arbitration agreement. The court ordered certain claims (reimbursement of expenses, wage statement claims, and unfair competition) to arbitration, but allowed wage claims to proceed in court under Labor Code section 229. It denied the motion to dismiss the representative PAGA claims, citing California Supreme Court precedent, and stayed both actions pending arbitration of individual claims.The Court of Appeal of the State of California, First Appellate District, Division One, reviewed these consolidated appeals. The court held that the plaintiff is a transportation worker exempt from the FAA because he played a direct and active role in the interstate movement of goods, even though his deliveries were intrastate and retail in nature. The court affirmed that the plaintiff has standing to pursue non-individual PAGA claims in court, following Adolph v. Uber Technologies, Inc. The order by the trial court was affirmed. View "Betanco v. Living Spaces Furniture, LLC" on Justia Law

In 2016, U.S. Customs and Border Protection faced a surge of individuals seeking admission at ports along the U.S.-Mexico border, often exceeding the capacity for safe processing. To manage this, the Department of Homeland Security instituted a “metering” policy that limited the number of people allowed to cross each day, with CBP officials stationed on the U.S. side of the border to prevent entry beyond daily capacity. The policy’s enforcement meant that some asylum seekers remained in Mexico, unable to present themselves for inspection or apply for asylum immediately.A group of asylum seekers and the advocacy organization Al Otro Lado filed a class action in the United States District Court for the Southern District of California, challenging the legality of metering. The District Court certified a class and granted summary judgment for the plaintiffs, declaring the government’s denial of inspection and asylum processing to those “in the process of arriving in the United States” to be unlawful. After the government rescinded the metering policy, the United States Court of Appeals for the Ninth Circuit affirmed in part, holding that an individual standing in Mexico who encounters a U.S. official at the border “arrives in the United States” for purposes of inspection and asylum eligibility.The Supreme Court of the United States reversed the Ninth Circuit’s decision. It held that under the Immigration and Nationality Act, an alien “arrives in the United States” only upon physically crossing the border. The statutory language does not entitle someone standing in Mexico to inspection or to apply for asylum, nor does it require U.S. officials to inspect such individuals. The Court concluded that the statutory provisions at issue do not have extraterritorial effect and that the metering policy, as applied, was not unlawful under the INA. The judgment was reversed and remanded. View "Mullin v. Al Otro Lado" on Justia Law

Robert Hossfeld received twelve telemarketing calls advertising Allstate Insurance products, despite having previously requested that Allstate not contact him. The calls were made by Atlantic Telemarketing Center, which had been subcontracted by Transfer Kings, a company retained by Allstate’s insurance agents, Fleming and Gilmond. Allstate’s internal do-not-call list included Hossfeld’s number months before the calls occurred. Neither Allstate nor its agents were aware that Atlantic was involved in marketing Allstate insurance until after Hossfeld initiated his lawsuit.Hossfeld sued Allstate in the United States District Court for the Northern District of Illinois, alleging violations of the Telephone Consumer Protection Act (TCPA) because Allstate failed to maintain an adequate do-not-call policy and permitted calls to be made to him after his request. He also sought class certification for other similarly affected individuals. The district court denied class certification, finding Hossfeld had not demonstrated that the proposed class was sufficiently numerous. On cross-motions for summary judgment, the district court ruled in Hossfeld’s favor, holding Allstate vicariously liable for Atlantic’s calls under agency law and awarding treble damages for willful violations.The United States Court of Appeals for the Seventh Circuit reviewed the case. The appellate court affirmed the denial of class certification, agreeing that Hossfeld failed to prove numerosity and impracticability of joinder. However, it reversed the district court’s summary judgment on liability, concluding that Hossfeld failed to show Allstate was liable for Atlantic’s calls under any theory of agency law, including subagency, apparent authority, or ratification. The Seventh Circuit clarified that the willfulness standard under the TCPA requires reckless or knowing conduct, not merely volitional acts. The court affirmed in part and reversed in part, directing judgment for Allstate. View "Hossfeld v Allstate Insurance Co." on Justia Law

A group of inmates incarcerated within Alabama’s state prison system filed a class action challenging the adequacy of mental health care provided by the Alabama Department of Corrections (ADOC). The plaintiffs, who suffer from serious mental illnesses, alleged that overcrowding, understaffing, and a series of systemic failures resulted in constitutionally deficient mental health services, contributing to a suicide rate far above the national average. Key alleged deficiencies included improper identification and classification of mental health needs, inadequate treatment plans, insufficient psychotherapy, lack of proper suicide risk management, improper use of segregation for mentally ill inmates, and the imposition of disciplinary sanctions for manifestations of mental illness.The United States District Court for the Middle District of Alabama managed the litigation in multiple phases. After a seven-week bench trial, the court found the ADOC liable under the Eighth Amendment for deliberate indifference to inmates’ serious mental health needs. The court then held extensive remedial proceedings, including further hearings and negotiations, and entered a comprehensive, system-wide remedial injunction. The court made detailed factual findings and, to comply with the Prison Litigation Reform Act (PLRA), issued particularized findings that the relief ordered was necessary, narrowly drawn, and the least intrusive means to remedy the constitutional violations. The court also adopted a monitoring plan to ensure compliance, involving external experts and a transition to internal oversight.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s liability findings and most aspects of the remedial and monitoring orders, holding that system-wide relief was appropriate given the systemic nature of the violations. However, the appellate court reversed certain remedial provisions where it found the relief exceeded what was necessary to correct the constitutional violations, particularly with respect to suicide-proofing cells and some staffing requirements, and as applied to a women’s facility where violations were not established. The case was remanded for modification in those limited respects. View "Braggs v. Commissioner, Alabama Department of Corrections" on Justia Law

A resident of St. Louis brought a class action lawsuit against the city, seeking a refund of fees paid for solid waste services. The plaintiff alleged that these fees were collected under the mistaken belief that the city was providing separate recycling and yard waste collection, which the city either failed to provide or did not provide consistently. The city had implemented a monthly solid waste services fee in 2010, increased it in 2017, and included the fee in residents’ water bills. Although the city at times collected recyclables and yard waste separately, it often did not, and ultimately terminated the program in 2025. The plaintiff argued that the city unjustly retained fees for services it did not render, seeking damages for herself and other residents.The Circuit Court of the City of St. Louis denied the city’s motion to dismiss, finding that the plaintiff’s claim for “money had and received” could proceed. The city then sought a writ of prohibition from the Missouri Court of Appeals, which was denied. The city subsequently sought relief from the Supreme Court of Missouri.The Supreme Court of Missouri held that the city is protected by sovereign immunity and that section 432.070 of the Missouri Revised Statutes bars the claim. The court found that the plaintiff’s allegations did not plead facts that would establish an exception to sovereign immunity for her claim and that no statutory or recognized common law exception applied. The court also concluded that the proprietary function exception did not apply, as solid waste collection is a governmental function. The court made its preliminary writ of prohibition permanent, directing that the plaintiff’s claim be dismissed. View "State ex rel. City of St. Louis vs. Whyte" on Justia Law

Technicians employed by the defendant performed installation, maintenance, inspection, testing, repair, and replacement of fire alarms, fire sprinklers, and security system equipment under contracts with public entities in New York. These contracts varied in their language regarding the payment of prevailing wages: some disclaimed any obligation to pay prevailing wages, some were silent, and a few expressly based payment on prevailing wage rates. All contracts included a clause providing that any action against the defendant had to be brought within one year of accrual.The plaintiffs brought a proposed class action in the United States District Court for the Northern District of New York, alleging, among other claims, that they were owed prevailing wages as third-party beneficiaries of the contracts. The District Court granted the defendant’s motion for partial summary judgment, finding that the breach of contract claims were time-barred by the contractual limitation period, that the contracts did not expressly entitle plaintiffs to prevailing wages, and, in the alternative, that plaintiffs were not covered by the prevailing wage law. On appeal, the United States Court of Appeals for the Second Circuit held that plaintiffs were covered by Labor Law § 220 but certified two questions to the New York Court of Appeals regarding the implicit inclusion of prevailing wage promises in public works contracts and the enforceability of shortened contractual limitation periods.The New York Court of Appeals held that the promise to pay prevailing wages is implicit in every public works contract covered by Labor Law § 220, regardless of whether that promise appears in the contract’s text. As a result, employees may bring third-party beneficiary breach of contract claims to enforce the prevailing wage requirement. The Court further held that contractual agreements to shorten the statute of limitations for such claims are unenforceable. The Court answered the first certified question in the affirmative and the second in the negative. View "Walton v Comfort Sys. USA (Syracuse), Inc." on Justia Law

Robert Cocom, a former airport janitor, brought a putative class action against his previous employer, ABM Aviation, Inc., alleging wage and hour violations. When he was hired, Cocom signed a Mutual Arbitration Agreement (MAA) requiring employment-related disputes to be resolved through arbitration. The MAA included waivers of class, collective, and representative actions, as well as a provision stating that arbitration awards would not have preclusive or precedential effect in other proceedings. Cocom’s lawsuit was originally filed in state court but was removed to federal court by ABM, which then moved to compel arbitration and strike the class claims.The United States District Court for the Central District of California denied ABM’s motion, finding the arbitration agreement both procedurally and substantively unconscionable. The court relied heavily on the California Court of Appeal’s decision in Cook v. University of Southern California, interpreting the MAA as having an overly broad scope, indefinite duration, and lack of mutuality, and concluding that certain waivers violated California law. Finding multiple provisions unconscionable, the district court declined to sever them and refused to enforce the MAA.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s judgment. The appellate court held that the MAA’s provisions were distinguishable from those in Cook, noting that the MAA was limited to employment-related disputes, thereby avoiding the overbreadth, indefinite duration, and mutuality issues identified in Cook. The Ninth Circuit also found that any potentially unconscionable waivers (such as those related to representative actions or public injunctive relief) were severable. The main holding was that the MAA was not substantively unconscionable and should be enforced, and the case was remanded for further proceedings. View "COCOM V. ABM AVIATION, INC." on Justia Law

A utility company, Southern California Gas (SoCalGas), entered into a 2022 franchise agreement with the City of Los Angeles, allowing it to install, maintain, and operate its natural gas system under city streets. In exchange, SoCalGas agreed to pay the City a franchise fee equal to 5.5% of its gross receipts from natural gas sales within the City. Of this, 3.5% was passed to SoCalGas customers as a surcharge, which was later approved by the California Public Utilities Commission (CPUC). The franchise agreement was adopted after extensive, arm’s-length negotiations and CPUC review.A putative class action was filed by a customer, alleging that the surcharge component of the franchise fee constituted an unlawful tax under article XIII C of the California Constitution because it was not submitted for voter approval. The plaintiff argued the fee should have been apportioned between charges for physical use of city property and charges for the general business privilege, with the latter portion requiring voter approval. The Superior Court for Los Angeles County granted summary judgment for the City, finding the franchise fee, including the surcharge, exempt from voter approval as a charge for the use of local government property under section 1, subdivision (e)(4) of article XIII C.The California Court of Appeal, Second Appellate District, affirmed the trial court’s judgment. The Court held that the franchise fee, including the portion passed through as a surcharge, was not a tax within the meaning of article XIII C, section 1, subdivision (e)(4), because it was compensation for the use of city property and not subject to voter approval. The Court further held that the fee did not need to be apportioned or shown to be reasonably related to the value of the franchise, but found that, even if such a requirement existed, the City met it through bona fide negotiations. View "Nguyen v. City of L.A." on Justia Law

Two individuals filed a lawsuit on behalf of themselves and a proposed class, alleging that a life insurance company’s “Trendsetter LB” term life insurance policy misrepresented its premium structure. The plaintiffs argued that policy language stating the annual premium was “excluding riders” and that additional accelerated death benefit riders were included at “no charge” was misleading. They claimed consumers were led to believe these extra benefits were free, when in fact the premium included undisclosed charges for these riders. The plaintiffs did not allege they were denied any promised benefits, but contended the policy failed to break down the cost of its bundled components, allegedly causing consumers to misunderstand their options and overpay compared to a more basic policy.The case began in Alameda County Superior Court. Plaintiffs sought class certification for claims under California’s Unfair Competition Law (UCL), focusing only on alleged misrepresentations in the policy’s standardized language. The trial court initially found ascertainability and numerosity met, but denied class certification for most claims, ruling that determining liability would require individualized inquiries into what information each customer received from agents or marketing materials. The court certified only a narrow claim regarding compliance with a statutory notice requirement, but later, at plaintiffs’ request, denied certification entirely when they clarified they did not intend to pursue that claim.The Court of Appeal of the State of California, First Appellate District, Division One, affirmed the trial court’s denial of class certification. The court held that the policy language was, at best, ambiguous and that resolving liability would depend not just on the form policy language but also on individualized evidence about communications with each purchaser. The court determined that common issues did not predominate and that the trial court did not abuse its discretion in denying certification. The judgment was affirmed. View "Guthrie v. Transamerica Life Ins. Co." on Justia Law

Employees participating in a 401(k) plan offered by their employer, a clinical laboratory company, brought a class action alleging that the plan’s fiduciaries breached their duties under ERISA by retaining two particular investment options: the Fidelity Freedom Funds and the Invesco Global Real Estate Fund. The plaintiffs argued that these funds underperformed compared to alternatives, were riskier, and that the plan’s managers failed to remove them despite subpar performance. They also claimed that internal policy statements required the funds’ removal and that the plan’s managers failed in their duty to monitor investments and breached trust obligations.The United States District Court for the District of New Jersey initially denied a motion to dismiss the case, allowing discovery to proceed. After discovery, the District Court granted summary judgment in favor of the defendants. The court found that the plan’s fiduciaries had fulfilled their obligations by hiring investment advisors, regularly reviewing investment performance, seeking relevant training, and following up on concerns regarding the challenged funds. The court concluded there was no breach of fiduciary duty or related failures.On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s grant of summary judgment de novo, considering all facts and inferences in favor of the plaintiffs. The Third Circuit held that ERISA’s fiduciary standard is process-oriented, not outcome-based. The Court found that the fiduciaries had used a prudent process—hiring advisors, critically assessing their recommendations, meeting with fund managers, and maintaining regular oversight—even if the investments did not always outperform alternatives. The Court further held that internal policy statements were nonbinding and that the fiduciaries did not abuse their discretion. Consequently, the Third Circuit affirmed the District Court’s summary judgment in favor of the defendants on all claims. View "Johnson v. Quest Diagnostics Inc" on Justia Law