Justia Class Action Opinion Summaries
Articles Posted in Class Action
Hiller v. Marin Municipal Water Dist.
A public agency adopted an ordinance to increase water service rates after following procedural steps, such as conducting a cost-of-service analysis, notifying the public, and holding hearings as required by Proposition 218 of the California Constitution. After adopting the new rates, the agency initiated a validation action in court to confirm the validity of the ordinance, providing notice to interested parties by publication in a local newspaper, as authorized by statute. No one responded to contest the action within the required time, so the court entered default judgment upholding the ordinance.Subsequently, an individual who had previously submitted administrative claims to the agency challenging the rates filed a class action and mandamus lawsuit seeking refunds and declaratory and injunctive relief, alleging violations of Proposition 218 and constitutional rights. The agency responded with a demurrer, arguing that the plaintiff's claims were barred by the prior validation judgment and the statutory scheme requiring such challenges be brought through validation procedures. The Marin County Superior Court agreed, sustaining the demurrer without leave to amend and finding that the plaintiff's opportunity to challenge the rates had been foreclosed by the unchallenged validation judgment.The California Court of Appeal, First Appellate District, Division One, reviewed the case. The court held that under Government Code section 53759 and the related validation statutes, any legal challenge to ordinances adopting water service fees must be brought through specified validation proceedings, including constitutional claims. Since the plaintiff neither intervened in the agency's validation action nor filed a timely reverse validation action, her claims were barred. The court also found that due process was satisfied by the published notice required by statute, and that mandamus proceedings are not exempt from these requirements. The appellate court affirmed the judgment in favor of the agency. View "Hiller v. Marin Municipal Water Dist." on Justia Law
Mebane v. GKN Driveline North America, Inc.
A former employee brought a class-action lawsuit against his previous employer, alleging that the company’s practices concerning rounding employees’ time entries and automatically deducting meal breaks resulted in violations of the Fair Labor Standards Act and the North Carolina Wage and Hour Act. The employer operated manufacturing facilities in North Carolina and used policies that rounded employee work time and deducted unpaid meal breaks regardless of whether an employee actually took the break. Plaintiffs argued these policies led to unpaid overtime and wages.The United States District Court for the Middle District of North Carolina initially certified two classes under Federal Rule of Civil Procedure 23 and conditionally certified a collective action under the FLSA. However, after further developments and evidence showing that individualized inquiries would be necessary to determine whether employees were harmed by the time-rounding and meal-deduction policies, and that not all employees suffered wage loss, the district court decertified the classes and collective action. Subsequently, the named plaintiffs settled their individual claims with the employer, and the district court dismissed all remaining substantive claims with prejudice.The United States Court of Appeals for the Fourth Circuit was asked to review the district court’s order decertifying the classes and collective action. The court held that because the plaintiff voluntarily settled his individual claims before filing the appeal, he lacked standing to challenge the district court’s decertification order. The court reasoned that once the individual claims underlying the request for class certification are settled or dismissed voluntarily, the plaintiff no longer retains a concrete interest sufficient to satisfy Article III’s case-or-controversy requirement. Accordingly, the Fourth Circuit dismissed the appeal for lack of jurisdiction. View "Mebane v. GKN Driveline North America, Inc." on Justia Law
Smith v. The Gap, Inc.
Gap, a major clothing retailer, launched an initiative in August 2021 to expand plus-size clothing options in its Old Navy stores. The company overestimated customer demand for these larger sizes, resulting in excess inventory that had to be sold at discounts. By early 2022, Gap reduced its in-store plus-size offerings and eventually limited extended sizing to online sales. In May 2022, Gap disclosed that these missteps negatively affected its financial results for the first quarter of the year.Investors who purchased Gap stock between November 24, 2021, and July 11, 2022, filed a putative securities class action in the United States District Court for the Eastern District of New York. They alleged that Gap and two senior executives violated the Securities Exchange Act of 1934 by failing to disclose problems with the initiative in various statements to investors. The district court dismissed the complaint under Rule 12(b)(6), concluding that the plaintiffs did not identify any false or misleading statements or adequately plead that the defendants acted with scienter (intent or recklessness).The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court’s dismissal. The appellate court held that the challenged statements—including risk disclosures, earnings call remarks, and press releases—were not false or misleading in context and did not obligate Gap to disclose the problems with the initiative. The court found that the statements at issue were either generic industry risks, unactionable opinions or puffery, or did not give rise to a duty to disclose additional information. The appellate court also concluded that the plaintiffs failed to allege facts supporting a strong inference of scienter and, accordingly, their control-person liability claims under Section 20(a) were properly dismissed. The judgment of the district court was affirmed. View "Smith v. The Gap, Inc." on Justia Law
THAKUR V. TRUMP
Several researchers at the University of California received multi-year federal grants from agencies including the Environmental Protection Agency, the National Science Foundation, and the National Endowment for the Humanities. In April 2025, these agencies terminated the research grants by issuing form letters, citing shifts in agency priorities and referencing multiple Executive Orders issued by the President, some of which explicitly aimed to eliminate diversity, equity, and inclusion (DEI) and related initiatives from the federal government. The affected researchers alleged these terminations resulted in lost funding, harm to their reputations, and disruption to their projects, with no ready alternative sources of support.The researchers filed a class action lawsuit in the United States District Court for the Northern District of California, asserting constitutional and statutory claims, including violations of the First Amendment and the Administrative Procedure Act (APA). The district court provisionally certified two classes: one consisting of researchers whose grants were terminated by form letter without grant-specific explanation (the Form Termination Class), and another whose grants were terminated specifically due to the DEI Executive Orders (the DEI Termination Class). The district court granted a preliminary injunction, ordering the reinstatement of the grants for both classes. The government appealed.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the plaintiffs had established Article III standing. It reversed the preliminary injunction for the Form Termination Class, concluding that the district court likely lacked jurisdiction over their APA claim because the claim was essentially contractual and thus barred by the Tucker Act. However, the Ninth Circuit affirmed the preliminary injunction for the DEI Termination Class, finding that the class was likely to succeed on its First Amendment claim because the grant terminations were based on viewpoint discrimination. The court remanded for further proceedings. View "THAKUR V. TRUMP" on Justia Law
Ewalt v. GateHouse Media Ohio Holdings II, Inc.
Plaintiffs filed a putative class action against GateHouse Media in Ohio state court, alleging claims that met the requirements for federal jurisdiction under the Class Action Fairness Act (CAFA). GateHouse timely removed the case to the United States District Court for the Southern District of Ohio, where the parties litigated for several years. The district court eventually denied class certification and, based on that denial, remanded the case to state court, concluding it could no longer exercise jurisdiction and declining to exercise supplemental jurisdiction over remaining claims.After the case returned to state court, it remained inactive until plaintiffs renewed their motion for class certification. GateHouse then removed the case to federal court a second time, asserting that this renewed motion provided a new basis for removal under CAFA. Plaintiffs moved to remand, arguing the removal was untimely. The district court denied the remand motion, finding that its earlier remand order had created ambiguity about federal jurisdiction and, under principles of equity, tolled the 30-day removal deadline. Plaintiffs sought and were granted interlocutory review by the United States Court of Appeals for the Sixth Circuit.The United States Court of Appeals for the Sixth Circuit held that the 30-day deadline for removal under 28 U.S.C. § 1446(b)(1) is strict and cannot be equitably tolled, as clarified by the Supreme Court in Enbridge Energy, LP v. Nessel ex rel. Michigan. The Sixth Circuit concluded that GateHouse’s second removal was untimely because the original complaint had already triggered the removal clock, and subsequent events, including renewed class certification efforts, did not restart it. The appellate court reversed the district court’s order and instructed that the case be remanded to state court. View "Ewalt v. GateHouse Media Ohio Holdings II, Inc." on Justia Law
Surgeon v. TKO Shelby, LLC
Plaintiffs received a promotional flyer advertising a car dealership event, which offered a chance to win one of several grand prizes. The flyer instructed recipients whose code matched a winning number to call a hotline and then visit the dealership to claim their prize. Plaintiffs alleged that the scratch-off numbers on all flyers matched the grand prize, misleading recipients, while defendants maintained that a separate activation code determined the actual prize, which was a nominal cash amount for all claimants. Approximately 50,000 flyers were sent, 2,118 people called the hotline, and records indicated 927 people visited the dealership. However, there were no records identifying those 927 individuals.The Superior Court in Gaston County initially certified a class of the 927 people who visited the dealership. Defendants appealed, and the Supreme Court of North Carolina vacated the certification due to inconsistencies between the class definition and the court’s analysis, remanding for clarification. On remand, the trial court again certified a class based on revised criteria: receiving the flyer, calling the hotline, and visiting the dealership. However, the trial court allowed a named plaintiff who had not personally called the hotline to remain as a representative, leading to further conflict in its reasoning. Defendants appealed the renewed certification order.The Supreme Court of North Carolina reviewed the case and held that, on the current record, class certification was improper. The Court found that the class was not ascertainable because there was no objective method to identify class members without individualized fact determinations, which would overwhelm common issues. The Court vacated the trial court’s class certification order and remanded for further proceedings, leaving open the possibility of addressing spoliation claims if pursued. View "Surgeon v. TKO Shelby, LLC" on Justia Law
Posted in:
Class Action, North Carolina Supreme Court
OLSON V. FCA US, LLC
Jeffrey Olson leased a Jeep Grand Cherokee from a car dealership under a lease agreement that included an arbitration provision and a delegation clause, which assigned questions about the scope of arbitration to an arbitrator. FCA US, LLC, the manufacturer of the Jeep, was not a signatory to the lease agreement. Olson later became the named plaintiff in a federal class-action lawsuit against FCA, alleging defects in the vehicle’s headrest system. FCA, not being a party to the lease, sought to compel Olson to arbitrate the dispute based on the arbitration agreement between Olson and the dealership.The United States District Court for the Eastern District of California denied FCA’s motion to compel arbitration. The district court found that FCA, as a non-signatory to the lease agreement, could not enforce the arbitration provision or its delegation clause against Olson. The court concluded that the arbitration agreement applied only to Olson and the dealership (including its employees, agents, successors, or assigns), and FCA did not qualify under any of those categories. Additionally, the court rejected FCA’s argument that it could use equitable estoppel to compel arbitration, holding that none of Olson’s claims were sufficiently intertwined with the lease agreement to justify such an exception under California law.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The Ninth Circuit held that FCA could not compel Olson to arbitrate because FCA was not a party to the arbitration agreement and no applicable exception—such as equitable estoppel—applied. The court clarified that, under both federal and California law, only parties to an arbitration agreement (or those qualifying under specific, limited exceptions) may enforce it. The court also rejected FCA’s reliance on Supreme Court precedent, finding it inapplicable to non-signatories in these circumstances. View "OLSON V. FCA US, LLC" on Justia Law
Boe v. Children’s Hosp. Colo.
The plaintiffs in this case are minor patients who had been receiving gender-affirming medical care at the TRUE Center for Gender Diversity, a specialized department at a major pediatric hospital serving the Rocky Mountain Region. Following a December 2025 declaration by the U.S. Secretary of Health and Human Services stating that medical gender-affirming care for minors was unsafe and could result in exclusion from federal health care payment programs, the hospital suspended such care for transgender patients under eighteen. The hospital continued to provide hormone therapy and puberty blockers to cisgender youth for other medical reasons. The plaintiffs, representing a class of similarly situated individuals, experienced immediate and significant emotional and physical harm as a result.The plaintiffs filed a class action in the District Court for the City and County of Denver seeking a preliminary injunction under the Colorado Anti-Discrimination Act (CADA) to require the hospital to resume medically necessary gender-affirming care. The trial court found that the plaintiffs were likely to succeed on the merits, faced irreparable harm, and lacked an adequate remedy at law, but denied the injunction. The court reasoned that granting the injunction was contrary to the public interest, the balance of equities favored the hospital, and the injunction was not sufficiently specific to preserve the status quo.The Supreme Court of Colorado, en banc, reviewed the trial court's denial for abuse of discretion. It concluded that the trial court misapplied the legal standards governing preliminary injunctions in discrimination cases, particularly regarding the public interest and balance of equities. The Supreme Court held that the plaintiffs satisfied all six required factors, including a reasonable probability of success on their CADA claim, and that the injunction would preserve the pre-suspension status quo. The trial court’s order was reversed, and the case was remanded with instructions to grant the preliminary injunction. View "Boe v. Children's Hosp. Colo." on Justia Law
Jackson v. Protas, Spivok & Collins LLC
Donte Jackson received a $30,000 loan from WebBank, which was later sold to Velocity Investments, LLC. After Jackson defaulted on the loan, Velocity, represented by the law firm Protas, Spivok & Collins LLC (PSC), sued Jackson in Maryland state court to collect the debt. Velocity eventually dismissed the state court suit with prejudice. Subsequently, Jackson brought a class action lawsuit against both Velocity and PSC, alleging that their practice of suing on time-barred debts was unlawful.In the United States District Court for the District of Maryland, both Velocity and PSC moved to compel arbitration based on an arbitration clause in Jackson’s original promissory note. The district court found that Velocity, as a subsequent holder of the note, was a party to the arbitration agreement but had waived its right to arbitrate by filing suit in state court. The court ruled that PSC was not a party to the agreement, as it did not fit the contractual definition of an entity “servicing” the note, which the court interpreted in accordance with Maryland law. Only PSC appealed the denial of its motion to compel arbitration.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s ruling de novo. The Fourth Circuit held that PSC, as the law firm representing Velocity, was not a party to the arbitration agreement because it did not “service” the note in the relevant contractual sense, which involves collecting and maintaining a payment schedule for the loan. The court concluded that the arbitration agreement covered only creditors and loan servicers, not lawyers. The Fourth Circuit affirmed the district court’s denial of PSC’s motion to compel arbitration. View "Jackson v. Protas, Spivok & Collins LLC" on Justia Law
Farella v. Anglin
Two individuals were arrested by the Bentonville Police Department in Arkansas and appeared before a state district court judge two days and one day after their respective arrests. During these initial hearings, the judge set bail amounts for each individual without providing them with legal representation. Only after setting bail did the judge determine that they were indigent and appoint counsel for future proceedings. Both individuals remained incarcerated for several weeks before ultimately pleading guilty and being sentenced to time served.Following their experiences, these individuals, acting on behalf of a class of similarly situated pretrial detainees, filed suit in the United States District Court for the Western District of Arkansas. They alleged that the judge’s practice of setting bail without first appointing counsel violated their rights under the Sixth and Fourteenth Amendments. They sought declaratory and injunctive relief requiring that indigent defendants be provided with counsel at the start of their initial bail hearings. The district court denied motions to dismiss, certified the class, and ultimately granted summary judgment in favor of the plaintiffs. The district court held that the plaintiffs’ right to counsel attached at the initial hearing and that the bail-setting constituted a critical stage, thus granting declaratory and injunctive relief against the judge.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the case. The Eighth Circuit held that the plaintiffs lacked Article III standing because they failed to show an ongoing or imminent injury that could be redressed by the prospective relief sought. The court found that the possibility of facing the same situation again was too speculative and that the requested relief would not redress any past harm already suffered. As a result, the Eighth Circuit vacated the district court’s judgment and remanded the case with instructions to dismiss for lack of standing. View "Farella v. Anglin" on Justia Law