Justia Class Action Opinion Summaries

Susan Carpenter, as trustee for the H. Joe King, Jr. Revocable Trust, sold two properties in North Carolina in April 2020. Both properties were part of homeowners’ associations managed by William Douglas Management, Inc. Carpenter paid fees for statements of unpaid assessments required for the sales, which she claimed were excessive under North Carolina law. She filed a class action lawsuit against William Douglas and NextLevel Association Solutions, Inc., alleging violations of state laws, including the prohibition of transfer fee covenants, the Unfair and Deceptive Trade Practices Act, and the Debt Collection Act, along with claims of negligent misrepresentation, unjust enrichment, and civil conspiracy.The case was initially filed in North Carolina state court but was removed to the United States District Court for the Western District of North Carolina. The district court dismissed Carpenter’s complaint for failure to state a claim, concluding that the fees charged were not transfer fees as defined by state law and that the companies were not deceptive or unfair in charging them.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court’s dismissal, holding that the fees charged for the statements of unpaid assessments did not qualify as transfer fees under North Carolina law. The court also found that the fees were not unfair or deceptive under the Unfair and Deceptive Trade Practices Act. Consequently, Carpenter’s additional claims of unjust enrichment, violation of the Debt Collection Act, negligent misrepresentation, and civil conspiracy were also dismissed, as they were contingent on the success of her primary claims. View "Carpenter v. William Douglas Management Inc" on Justia Law

Elizabeth Perez, a former employee of Rose Hills Company, filed a class action lawsuit on behalf of herself and similarly situated employees, alleging violations of California wage-and-hour laws. The complaint did not specify the amount in controversy or the frequency of the alleged violations. Rose Hills removed the case to federal court under the Class Action Fairness Act (CAFA), which allows removal if the amount in controversy exceeds $5 million.The United States District Court for the Central District of California remanded the case to state court, stating that Rose Hills did not meet CAFA’s $5 million amount-in-controversy requirement. The district court found that Rose Hills failed to provide evidence justifying its assumed violation rate, which was used to calculate the amount in controversy.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that a removing defendant under CAFA is permitted to rely on reasonable assumptions based on the plaintiff’s complaint to calculate the amount in controversy. The court found that Rose Hills’ approach, which included assumptions about the violation rate tethered to the language of the complaint, was reasonable. The district court erred by requiring Rose Hills to provide evidence supporting its assumed violation rate.The Ninth Circuit vacated the district court’s remand order and remanded the case for further proceedings, instructing the district court to evaluate whether Rose Hills’ violation-rate assumption was a reasonable interpretation of the complaint. The court emphasized that assumptions need not be proven with evidence if they are reasonable interpretations of the complaint’s allegations. View "Perez v. Rose Hills Company" on Justia Law

Bradley Patton was arrested in Rutherford County, Tennessee, and charged with drug and firearm offenses. He posted bail multiple times, but his bail was eventually increased to $126,000. Under local rules, because his bail exceeded $75,000, he had to prove in a hearing that the bail money was not derived from criminal activities. Patton filed a class-action lawsuit in federal court, claiming that this local rule violated his due-process and Eighth Amendment rights.The United States District Court for the Middle District of Tennessee dismissed Patton's claims, ruling that they were moot because he had been released from pretrial custody and there was no ongoing harm. The court also found that Patton could not rely on the putative class's standing to preserve his claims and rejected his argument that the claims were capable of repetition yet evading review.The United States Court of Appeals for the Sixth Circuit reviewed the case and held that Patton's claims fell within the "inherently transitory" exception to mootness for class-action claims. The court noted that pretrial detention is inherently temporary and that other class members would likely suffer the same injury. The court also found that the district court's decision to reserve the deadline for filing a motion for class certification meant that Patton should not be penalized for not filing such a motion. The Sixth Circuit reversed the district court's judgment and remanded the case for further proceedings. View "Patton v. Fitzhugh" on Justia Law

Plaintiffs, representing a putative class, filed an antitrust lawsuit against Grubhub Inc., Postmates Inc., and Uber Technologies, Inc. (collectively, "Defendants"). The plaintiffs alleged that the defendants violated Section 1 of the Sherman Antitrust Act and its state analogues by entering into no-price competition clauses (NPCCs) with restaurants, which prevented the restaurants from offering lower prices through other channels. The plaintiffs claimed that these NPCCs led to artificially high prices for restaurant meals. The class included customers who purchased takeout or delivery directly from restaurants subject to NPCCs, customers who dined in at such restaurants, and customers who used non-defendant platforms to purchase from these restaurants.The United States District Court for the Southern District of New York denied the defendants' motion to compel arbitration. The court held that the scope of the arbitration clauses was an issue for the court to decide and that the clauses did not apply to the plaintiffs' claims as they lacked a nexus to the defendants' Terms of Use. The court also found that the plaintiffs had not agreed to Grubhub's Terms of Use.The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the district court's decision in part, ruling that the question of arbitrability for the plaintiffs' claims against Grubhub is for the court to decide and that Grubhub's arbitration clause does not apply to the plaintiffs' antitrust claims. However, the court reversed the district court's decision in part, finding that Grubhub had established an agreement to arbitrate with the plaintiffs and that the threshold question for the plaintiffs' claims against Uber and Postmates is for the arbitrator to decide. The case was remanded for further proceedings consistent with this opinion. View "Davitashvili v. Grubhub" on Justia Law

In 2020 and 2021, Rohan Dhruva and Joshua Stern, residents of California, created accounts and subscribed to CuriosityStream, an online streaming service. They later discovered that CuriosityStream was sharing their event data and other identifiers with Meta, which they claimed violated the federal Video Privacy Protection Act and California state law. Consequently, they filed a putative class action lawsuit in Maryland, where CuriosityStream is headquartered.The United States District Court for the District of Maryland denied CuriosityStream's motion to compel arbitration. The court acknowledged that the website provided adequate notice of the Terms of Use through a conspicuous hyperlink but concluded that users were not given clear notice that clicking the "Sign up now" button constituted agreement to the Terms of Use. CuriosityStream's motion for reconsideration was also denied.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court concluded that Dhruva and Stern had reasonable notice that registering for the streaming service would constitute assent to the website’s Terms of Use, which included an arbitration clause. The court held that the design and content of the website provided sufficient notice of the terms and that Dhruva and Stern manifested their assent by registering with the website. Consequently, the Fourth Circuit reversed the district court's order denying the motion to compel arbitration and remanded the case for further proceedings. View "Dhruva v. CuriosityStream, Inc." on Justia Law

Plaintiffs, business entities owning recovery rights assigned by health insurers and other third-party Medicare payors, alleged that Defendants, including a drug manufacturer, a specialty pharmacy, and healthcare nonprofits, colluded to inflate the price and quantity of the drug Xenazine. This alleged scheme purportedly violated the Racketeer Influenced and Corrupt Organizations Act (RICO) and various state laws, causing the Assignors to reimburse inflated Xenazine prescriptions at supra-competitive prices.The United States District Court for the Eastern District of Virginia dismissed the class-action complaint with prejudice, concluding that Plaintiffs failed to adequately allege that Defendants’ conduct proximately caused their injuries. The court emphasized that RICO’s proximate-causation requirement focuses on the directness of the harm, not its foreseeability. The court found the alleged causal chain too attenuated, involving numerous independent actors like physicians and pharmacists, and dismissed the state-law claims for similar reasons.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s dismissal of the federal RICO claims, agreeing that Plaintiffs failed to establish proximate causation. The court noted that the alleged scheme had more direct victims, such as distributors and wholesalers, and that the volume of Xenazine prescriptions depended on the independent decisions of doctors. The court also affirmed the dismissal of the state-law consumer-protection and unjust-enrichment claims, finding them insufficiently pleaded.The Fourth Circuit reversed the district court’s conclusion that Plaintiffs had standing to bring claims on behalf of unidentified assignors, remanding those claims for dismissal without prejudice. The court upheld the district court’s denial of post-judgment relief and leave to amend the complaint, concluding that further amendment would be futile. View "MSP Recovery Claims, Series LLC v. Lundbeck LLC" on Justia Law

Plaintiffs sued Qualcomm Inc., alleging that its business practices violated state and federal antitrust laws. These practices included Qualcomm’s “no license, no chips” policy, which required cellular manufacturers to license Qualcomm’s patents to purchase its modem chips, and alleged exclusive dealing agreements with Apple and Samsung. The Federal Trade Commission (FTC) had previously challenged these practices, but the Ninth Circuit reversed the district court’s ruling in favor of the FTC, holding that Qualcomm did not violate the Sherman Act.The district court in the current case certified a nationwide class, but the Ninth Circuit vacated the class certification order and remanded to consider the viability of plaintiffs’ claims post-FTC v. Qualcomm. On remand, plaintiffs proceeded with state-law claims under California’s Cartwright Act and Unfair Competition Law (UCL). The district court dismissed the tying claims and granted summary judgment on the exclusive dealing claims. The court found that the Cartwright Act did not depart from the Sherman Act and that plaintiffs failed to show market foreclosure or anticompetitive impact in the tied product market. The court also rejected the UCL claims, finding no fraudulent practices and determining that plaintiffs could not seek equitable relief.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal of the tying claims and the summary judgment on the exclusive dealing claims under the Cartwright Act. The court held that Qualcomm’s “no license, no chips” policy was not anticompetitive and that plaintiffs failed to show substantial market foreclosure or antitrust injury. The court also affirmed the rejection of the UCL claims but vacated the summary judgment on the UCL unfairness claim related to exclusive dealing, remanding with instructions to dismiss that claim without prejudice for refiling in state court. View "KEY V. QUALCOMM INCORPORATED" on Justia Law

In the spring of 2020, Colorado State University (CSU) transitioned from in-person to online learning due to the COVID-19 pandemic. Renee Alderman and Tyler Stokes, both students, filed class action lawsuits seeking refunds for tuition and fees paid for that semester, alleging CSU breached its contract to provide in-person learning and access to facilities. They also claimed unjust enrichment. The district court dismissed the breach of contract claims, citing CSU's statutory authority to suspend operations during unforeseen calamities, and later dismissed the unjust enrichment claims, ruling that the contract covered the same subject matter.Alderman appealed, and the Colorado Court of Appeals reversed the district court's dismissal of her unjust enrichment claims, holding that CSU's invocation of the statute rendered the contract unenforceable, thus allowing the unjust enrichment claims to proceed.The Supreme Court of Colorado reviewed the case and concluded that the lower court erred in holding the contract unenforceable. The court held that the statutory provision allowing CSU to suspend operations was part of the contract, and the inability to state a breach of contract claim did not render the contract itself unenforceable. Consequently, Alderman's unjust enrichment claims failed as a matter of law because a valid, enforceable contract existed covering the same subject matter. The Supreme Court reversed the appellate court's decision and directed reinstatement of the district court's judgment in favor of CSU. View "Bd. of Governors of the Colo. State Univ. v. Alderman" on Justia Law

A cyberattack on California Pizza Kitchen, Inc. (CPK) in September 2021 compromised the personal information of over 100,000 former and current employees. This led to multiple class action lawsuits against CPK, alleging negligence and other claims. The consolidated plaintiffs reached a settlement with CPK, offering cash payments and credit monitoring services to class members, with CPK required to make payments only to those who submitted valid claims. The settlement's monetary value was estimated at around $950,000, while the attorneys sought $800,000 in fees.The United States District Court for the Central District of California approved the settlement but reserved judgment on the attorneys' fees until after the claims process concluded. The consolidated plaintiffs reported a final claims rate of 1.8%, with the maximum monetary value of the claims being around $950,000. Despite expressing concerns about the scope of attorneys' fees, the district court ultimately awarded the full $800,000 in fees and costs.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's approval of the class settlement, finding that the district court had properly applied the heightened standard to review the settlement for collusion and had not abused its discretion in finding the settlement fair, reasonable, and adequate. However, the Ninth Circuit reversed the fee award, noting that the district court had not adequately assessed the actual value of the settlement and compared it to the fees requested. The case was remanded for the district court to determine the settlement's actual value to class members and award reasonable and proportionate attorneys' fees. View "IN RE: CALIFORNIA PIZZA KITCHEN DATA BREACH LITIGATION" on Justia Law

Lillian Vogt purchased a used van from a dealer and later discovered that the dealer had bought the van from a representative of Progressive Casualty Insurance Company. The van had been classified as a total loss by Progressive but was sold with a clean title instead of a salvage title. Vogt believed that Progressive had mistitled the van and filed claims of fraud, negligent misrepresentation, negligence, and negligence per se against the company. She also sought to certify two classes of individuals who purchased and owned vehicles that Progressive allegedly mistitled in the same manner.The United States District Court for the Eastern District of Missouri denied class certification for both classes. The court concluded that issues common to the putative class members would not predominate over member-specific issues of reliance or causation. Vogt was granted leave to appeal this decision.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of class certification for abuse of discretion. The appellate court agreed with the district court, affirming its decision. The court held that the fraud and negligent misrepresentation claims required proof of reliance, which was a member-specific question unsuitable for class treatment. Similarly, the negligence and negligence per se claims required proof of causation, which also entailed proof of reliance. The court concluded that individualized inquiries into each putative class member’s reasons for purchasing their vehicles would be necessary, making class certification inappropriate. The decision of the district court was affirmed. View "Vogt v. Progressive Casualty Insurance Company" on Justia Law