Justia Class Action Opinion Summaries

The case involved a lawsuit against Meta Platforms, Inc. (formerly known as Facebook) by a class of advertisers who claimed that Meta misrepresented the "Potential Reach" of advertisements on its platforms. The plaintiffs alleged that Meta falsely claimed that Potential Reach was an estimate of people, when in fact, it was an estimate of accounts.The United States Court of Appeals for the Ninth Circuit affirmed the district court's order certifying one class of advertisers (the damages class) who sought compensation for fraudulent misrepresentation and concealment. The court stated that the misrepresentation was a common issue for the class and that the district court properly determined that the element of justifiable reliance was capable of classwide resolution.However, the court vacated the district court's order certifying another class of advertisers (the injunction class) who sought injunctive relief. The court asked the lower court to reconsider whether the named plaintiff, Cain Maxwell, had Article III standing to seek an injunction. The case was remanded for further proceedings. View "DZ Reserve v. Meta Platforms, Inc." on Justia Law

The case at hand involves a putative class action brought against RAC Acceptance East, LLC, by Shannon McBurnie and April Spruell. The plaintiffs argue that two fees imposed by RAC, operators of retail stores that lease household and electronic items through rent-to-own contracts, violated California consumer protection laws. RAC sought to compel arbitration, citing an arbitration agreement with the plaintiffs. The district court denied RAC's motion, and RAC appealed the decision.RAC argued that a recent Supreme Court decision, Viking River Cruises, Inc. v. Moriana, implicitly abrogated a prior Ninth Circuit decision, Blair v. Rent-A-Center, Inc., which held that RAC's arbitration agreement was unenforceable under California law. The Ninth Circuit disagreed, stating that Viking River was not irreconcilable with Blair, and that Viking River dealt with different claims from those at issue in this case. Therefore, Blair remained binding.RAC also argued that the plaintiffs' claim for public injunctive relief was mooted by a Consent Decree it entered into with the California Attorney General. The court disagreed, stating that the Consent Decree did not address whether the $45 processing fee in this case violates the law, and therefore, the challenge to the fee was not moot.However, RAC contended that the plaintiffs lacked standing to challenge a $1.99 expedited payment fee because Spruell did not actually pay the fee. The court remanded this issue to the district court for further consideration. As a result, the Ninth Circuit affirmed the district court's denial of RAC's motion to compel arbitration in part and remanded the case for further proceedings on the issue of the standing of the plaintiffs to challenge the $1.99 expedited payment fee. View "McBurnie v. RAC Acceptance East, LLC" on Justia Law

In this case, five former customers of Peregrine Financial Group, Inc., a defunct futures commission merchant, filed a class action lawsuit against various defendants, including JPMorgan Chase Bank and National Futures Association. They claimed that their investments were wiped out due to fraudulent activities by Peregrine's CEO. The United States District Court for the Southern District of New York dismissed the federal claims as time-barred and declined to exercise supplemental jurisdiction over the state-law claims.On appeal, the United States Court of Appeals for the Second Circuit affirmed the lower court's decision. The main issue addressed by the Second Circuit was whether a party could compel a district court to exercise subject-matter jurisdiction on a theory of jurisdiction that the party raised untimely.The Court held that a party may not do so. The Court distinguished between objecting to a federal court's exercise of jurisdiction, which a party could do at any stage in the litigation, and invoking the district court’s jurisdiction, which can be forfeited if not raised timely. Therefore, although federal courts must ensure they have jurisdiction, there is no corresponding obligation to find and exercise jurisdiction on a basis not raised by the parties. The Court concluded that the district court was within its discretion to decline to consider the untimely raised theory of jurisdiction. View "Behrens v. JPMorgan Chase Bank, N.A." on Justia Law

The plaintiff, Adan Ortiz, worked for two companies, GXO Logistics Supply Chain, Inc., and Randstad Inhouse Services, LLC, both of which were his former employers. Ortiz's role involved handling goods in a California warehouse facility operated by GXO. The goods, primarily Adidas products, were received from mostly international locations and stored at the warehouse for several days to a few weeks before being shipped to customers and retailers in various states.Ortiz filed a class action lawsuit against his former employers alleging various violations of California labor law. The defendants moved to compel arbitration pursuant to an arbitration agreement in Ortiz's employment contract. Ortiz opposed this on the grounds that the agreement could not be enforced under federal or state law.The United States Court of Appeals for the Ninth Circuit affirmed in part the district court's order denying the appellants' motion to compel arbitration. It concluded that Ortiz belonged to a class of workers engaged in foreign or interstate commerce and was therefore exempted from the Federal Arbitration Act (FAA). The court reasoned that although Ortiz's duties were performed entirely within one state's borders, his role facilitated the continued travel of goods through an interstate supply chain, making him a necessary part of the flow of goods in interstate commerce. The court also rejected the argument that an employee must necessarily be employed by a transportation industry company to qualify for the transportation worker exemption. View "ORTIZ V. RANDSTAD INHOUSE SERVICES, LLC" on Justia Law

In a complex and long-running series of legal disputes over attorney fees, two law firms, Shields Law Group and Paul Byrd Law Firm, and another firm, Hossley-Embry LLP, (collectively referred to as the "Objecting Firms") challenged the district court's approval of a settlement agreement among other firms involved in the litigation. The dispute arose from a class action lawsuit against Syngenta, an agricultural company, which was settled for $1.51 billion in 2018. One-third of the settlement was allocated for attorneys' fees, but the distribution of these fees among the numerous law firms involved in the case led to additional litigation.The district court approved a settlement agreement in which a group of firms (the Appellee Parties) agreed to pay $7 million to another firm, Watts Guerra. The Objecting Firms challenged this decision, arguing that it effectively reallocated money among the various pools of attorney fees. However, the Appellate Court concluded that the Objecting Firms lacked standing to challenge the district court's approval of the settlement agreement because they were not affected by it. The court also found that the Objecting Firms' challenges to the disbursement orders were moot. As a result, the court dismissed the appeals. View "SHIELDS LAW GROUP, LLC v. STUEVE SIEGEL HANSON LLP" on Justia Law

A massage parlor, Elegant Massage LLC, filed a class action lawsuit against State Farm Mutual Automobile Insurance Company, asserting claims of breach of contract and other related claims. The suit stemmed from State Farm's denial of insurance coverage to businesses that had to shut down partially or fully due to Virginia executive orders during the COVID-19 pandemic. Elegant Massage claimed that the forced closure constituted a "direct physical loss" under its insurance policy. The district court certified the class and denied State Farm’s motion to dismiss. State Farm appealed.The United States Court of Appeals for the Fourth Circuit used its pendent appellate jurisdiction to review the district court's denial of State Farm’s motion to dismiss in conjunction with the appealable class certification order. The appellate court referred to the precedent set in Uncork & Create LLC v. Cincinnati Insurance Co., which held that a similar business closure during the pandemic did not constitute a "direct physical loss" requiring material destruction or harm to the property. The court found that this precedent was directly applicable to the case at hand.Consequently, the court of appeals held that the district court had erred in denying State Farm's motion to dismiss. It ruled that the temporary closures ordered by the executive did not result in a "direct physical loss" under the policy terms. As a result, the court also found no basis for class certification. The court reversed the district court’s decisions and instructed it to dismiss the entire case. View "Elegant Massage, LLC v. State Farm Mutual Automobile Insurance Co." on Justia Law

In response to the COVID-19 pandemic, Ohio State University suspended in-person instruction, transitioned to virtual learning, restricted campus access, and provided limited refunds to students. Brooke Smith, a student at the university, filed a class-action lawsuit against the university, alleging breach of contract, unjust enrichment, and conversion. Smith argued that students had lost the benefits of their education without sufficient refunds.The Supreme Court of Ohio considered whether discretionary immunity, which shields the state from lawsuits for certain highly discretionary decisions, was a jurisdictional bar or an affirmative defense to suits brought against the state. The court held that discretionary immunity was indeed a jurisdictional bar, not an affirmative defense. This means that when the state makes highly discretionary decisions, such as its response to the COVID-19 pandemic, the Court of Claims does not have jurisdiction as the state has not waived its sovereign immunity for those decisions.However, the court noted that discretionary immunity is not absolute and does not extend to the negligent actions of the state's employees and agents in the performance of these activities. The court reversed the judgment of the Tenth District Court of Appeals, which had found that discretionary immunity was an affirmative defense, and remanded the case back to that court to determine whether Ohio State University was protected by discretionary immunity in its response to the COVID-19 pandemic. View "Smith v. Ohio State Univ." on Justia Law

The case involves a group of 214 plaintiffs who filed a lawsuit against Devon Energy Production Company, L.P. in a Texas state court, alleging that Devon had underpaid them over $100 million in oil-and-gas royalties. Devon, a citizen of Oklahoma, removed the case to federal court under the Class Action Fairness Act (CAFA). The plaintiffs sought to have the case remanded to the state court based on CAFA’s “local controversy” exception. The district court agreed and ordered the case to be remanded.On appeal, the United States Court of Appeals for the Fifth Circuit disagreed with the district court's interpretation of the statute. The appellate court found that not all plaintiffs had incurred their "principal injuries" (financial harm from Devon's alleged underpayment of royalties) in Texas, as required under the "local controversy" exception of CAFA.Accordingly, the appellate court vacated the district court's judgment remanding the case to state court and directed that the case be reinstated on the district court's docket. This ruling signifies that the case will proceed in federal court, not state court. The court's ruling also clarified an important aspect of the CAFA's "local controversy" exception, specifically that all plaintiffs must have incurred their "principal injuries" in the state where the action was originally filed for the exception to apply. View "Cheapside Minerals v. Devon Energy" on Justia Law

The Eleventh Circuit Court of Appeals ruled on a class action lawsuit that involved a life insurance policy dispute between plaintiff Worth Johnson and defendant Protective Life Insurance Company. Johnson alleged that Protective breached its contract by not reassessing and adjusting its cost of insurance (COI) rates based exclusively on expectations of future mortality experience. The district court granted Protective’s motion for judgment on the pleadings, concluding that Protective did not breach its insurance contract.On appeal, the Eleventh Circuit affirmed the district court's decision in part, agreeing that the policy did not require Protective to reassess and redetermine its COI rates based exclusively on its expectations as to future mortality experience. However, the court reversed the district court's dismissal of Johnson's alternative claim that Protective did reassess and redetermine its COI rates, but ignored its expectations as to future mortality experience when doing so. The court remanded the case for further proceedings consistent with its ruling. View "Johnson v. Protective Life Insurance Company" on Justia Law

In this case, there were three separate class action lawsuits filed against Costa Del Mar, Inc., a sunglasses manufacturer, for allegedly deceptive warranty and repair policies. Each of the named plaintiffs purchased Costa sunglasses and were charged up to $105.18 to repair their sunglasses, despite the company's lifetime warranties that they claimed required the company to repair their sunglasses either free-of-charge or for a nominal fee. The plaintiffs sought both monetary damages and injunctive relief. The district court approved a settlement agreement that provided over $32 million in monetary relief and injunctive relief. However, the United States Court of Appeals for the Eleventh Circuit vacated this decision, reasoning that the named plaintiffs lacked Article III standing to pursue injunctive relief because none of them alleged any threat of future injury. The court remanded the case back to the district court to reconsider its approval of the settlement agreement, taking into account that it could not consider the injunctive relief's value in its determination that the settlement was fair, reasonable, and adequate. View "Smith v. Miorelli" on Justia Law