Justia Class Action Opinion Summaries

A group of 169 individuals who worked at the Clark County Government Center in Las Vegas brought claims alleging that they suffered serious injuries due to exposure to toxic chemicals, including polychlorinated biphenyls (PCBs), at their workplace. The site of the Government Center had previously been used as a rail yard by Union Pacific Railroad, and plaintiffs alleged that Union Pacific dumped waste, including PCBs manufactured by the former Monsanto Company, at the site. Plaintiffs asserted that Monsanto’s corporate successors inherited liability for harms caused by the production, sale, and distribution of PCBs, which allegedly caused a range of health issues for those exposed.The plaintiffs initially filed suit in Nevada state court against multiple defendants, including Union Pacific, the Las Vegas Downtown Redevelopment Agency, and Monsanto’s successors. The claims sought compensatory and punitive damages for injuries stemming from the alleged contamination. Monsanto’s successors removed the action to the United States District Court for the District of Nevada under the Class Action Fairness Act (CAFA). The plaintiffs moved to remand the case back to state court, and the District Court granted the motion, finding that the local controversy exception to CAFA applied since the alleged injuries were localized to Clark County.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s remand order de novo. The Ninth Circuit held that CAFA’s local controversy exception did not apply because the principal injuries resulting from Monsanto’s conduct were not shown to have been incurred primarily in Nevada. The court found that plaintiffs’ allegations described nationwide distribution and harm from PCBs, with no facts indicating that Nevada experienced principal or unique injuries. Therefore, the Ninth Circuit reversed the District Court’s order remanding the case and ordered the case to proceed in federal court. View "EMPLOYEES AT THE CLARK COUNTY GOVERNMENT CENTER V. MONSANTO COMPANY" on Justia Law

The plaintiff held a variable-rate credit card issued by a bank, with an agreement specifying that the interest rate for each billing cycle would be determined by adding a constant margin to the U.S. Prime Rate as published in The Wall Street Journal on the last day of each month. When the Federal Reserve increased the Federal Funds Rate multiple times from March 2022 to July 2023, the Prime Rate—and consequently, the plaintiff’s credit card interest rate—increased significantly. The new, higher rate was applied to the cardholder’s outstanding balances for the entire billing cycle, including balances incurred before the Prime Rate increased. The plaintiff, dissatisfied with paying higher interest on previous balances, filed a class action alleging that the bank’s method of calculating and applying the interest rate violated the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act) and California’s Unfair Competition Law.The United States District Court for the Northern District of California dismissed the case under Rule 12(b)(6), concluding that the bank’s method fell within a statutory exception in the CARD Act. The court found that the credit card agreement’s use of the Prime Rate, which is publicly available and not controlled by the bank, satisfied the CARD Act’s exception for variable rates tied to an external index.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the dismissal de novo. The appellate court held that the agreement complied with 15 U.S.C. § 1666i-1(b)(2), as the only variable affecting the rate was the Prime Rate, which was not under the bank’s control. The court found no violation of the CARD Act and affirmed the district court’s dismissal, holding that the bank’s method of setting variable rates according to the Prime Rate was lawful under the statute’s exception. View "MILLIKEN V. BANK OF AMERICA, N.A." on Justia Law

A group of unhoused veterans with severe disabilities and mental illnesses sued the United States Department of Veterans Affairs (VA) and the Department of Housing and Urban Development (HUD), seeking to restore the West Los Angeles VA Grounds for its intended use: housing disabled veterans. The VA had leased portions of this land to third parties—including the Regents of the University of California, Brentwood School, and Bridgeland Resources LLC—for uses that did not principally benefit veterans. Plaintiffs argued that the lack of supportive housing denied meaningful access to VA healthcare, violated the Rehabilitation Act, and placed them at serious risk of institutionalization. They also challenged VA policies that counted disability benefits as income, restricting access to supportive housing, and claimed that certain land-use agreements violated the Administrative Procedures Act (APA). Additionally, they asserted that the original 1888 Deed created a charitable trust that the VA had breached.The United States District Court for the Central District of California held a four-week bench trial, finding that the VA’s land-use leases with UCLA, Brentwood School, and Bridgeland Resources LLC were unlawful, voided these leases, and enjoined the VA from renegotiating them. The court certified a plaintiff class, ordered the VA to build supportive housing, found the VA and HUD violated the Rehabilitation Act in several respects, and determined that the VA had breached fiduciary duties under a charitable trust theory, invalidating certain leases on that basis as well.On review, the United States Court of Appeals for the Ninth Circuit affirmed in part, reversed in part, vacated in part, and remanded. The Ninth Circuit held that federal courts retained jurisdiction over plaintiffs’ Rehabilitation Act claims, upheld class certification, and affirmed findings of meaningful access, Olmstead, and facial discrimination under the Rehabilitation Act against the VA. The court reversed judgment against HUD, and also reversed the charitable trust claim, finding no judicially enforceable fiduciary duties under the Leasing Act. The court vacated related injunctive relief and judgments based on the charitable trust theory, including those against UCLA, Brentwood, and Bridgeland. The injunctions were modified, allowing the VA to renegotiate leases if compliant with statutory requirements. View "Powers v. McDonough" on Justia Law

Ryan O’Donnell and Michael Goree each had their vehicles disposed of by the City of Chicago after failing to pay multiple traffic tickets. The City acted under a municipal code provision that allows for immobilization, towing, and eventual disposition of vehicles registered to owners with outstanding violations. O’Donnell’s vehicle was sold to a towing company at scrap value; Goree’s vehicle was relinquished to a lienholder. Neither was compensated or had proceeds offset against their ticket debt.After these events, O’Donnell and Goree filed a putative class action in the United States District Court for the Northern District of Illinois, Eastern Division. Their complaint alleged that the City’s forfeiture scheme was facially unconstitutional under the Fifth Amendment’s Takings Clause and the Illinois constitution, and included a state-law unjust enrichment claim. They also asserted a Monell claim against the towing company, URT United Road Towing, Inc. The district court dismissed all claims for failure to state a claim, finding that the vehicle forfeiture under the traffic code was not a taking.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s dismissal de novo. The appellate court held that the City’s graduated forfeiture scheme is an exercise of its police power to enforce traffic laws rather than a taking for public use. The court reasoned that this type of law enforcement forfeiture does not trigger the Takings Clause of either the federal or Illinois constitutions. The court further found that because there was no constitutional violation, the plaintiffs’ Monell and unjust enrichment claims also failed. The Seventh Circuit affirmed the district court’s dismissal of all claims. View "O'Donnell v City of Chicago" on Justia Law

Two commercial truck drivers, residents of Connecticut, began working as delivery drivers for a baked goods company through a staffing agency, classified as W-2 employees. After several months, the company required them to create corporations and enter into “Distributor Agreements” in their capacities as presidents of those corporations to continue working. These agreements included mandatory arbitration clauses and disclaimed an employee-employer relationship. Despite the new contractual arrangement, the drivers’ daily responsibilities remained unchanged, consisting of picking up baked goods from the company’s warehouse and delivering them to retail outlets.Seeking relief under Connecticut wage and overtime laws, the drivers initiated a putative class action in Connecticut Superior Court. The baked goods company removed the case to the United States District Court for the District of Connecticut, invoking diversity jurisdiction. The company then moved to compel arbitration pursuant to the contractual arbitration clauses. The drivers opposed, arguing that the agreements were “contracts of employment” exempt from the Federal Arbitration Act (FAA) under § 1, that they were not bound in their individual capacities, and that the clauses were unenforceable. The District Court ruled in favor of the company, granting the motion to compel arbitration, and held that the agreements were not “contracts of employment” under § 1 of the FAA.On interlocutory appeal, the United States Court of Appeals for the Second Circuit reviewed the District Court’s order de novo. The Second Circuit held that the agreements, though signed by corporate entities created at the company’s request, were “contracts of employment” within the meaning of § 1 of the FAA, as they were contracts for the performance of work by workers. Consequently, the court vacated the District Court’s order compelling arbitration and remanded for further proceedings. View "Silva v. Schmidt Baking Distribution, LLC" on Justia Law

Two individuals brought a class action against Amazon, alleging that its Virtual Try-On (VTO) feature—used to preview makeup and eyewear products by rendering them on users’ faces via their mobile devices—violated the Illinois Biometric Information Privacy Act (BIPA). The VTO software, developed both in-house and by a third party, captured users’ facial geometry to overlay products for virtual preview. The plaintiffs claimed Amazon collected, stored, and used their facial data and that of many others in Illinois without proper notice, informed consent, or the creation of required data retention and destruction policies as mandated by BIPA.After removal from Illinois state court to the United States District Court for the Northern District of Illinois, the plaintiffs moved for class certification under Federal Rule of Civil Procedure 23(b)(3). The district court certified a class of all individuals who used Amazon’s VTO feature in Illinois after September 7, 2016. The district court found the class satisfied the requirements of numerosity, commonality, typicality, and adequacy, and that common questions—primarily concerning the VTO’s functionality and Amazon’s use of biometric data—predominated over individual questions such as location and damages. It also found a class action was superior due to the size and cost of potential individual litigation.On interlocutory appeal, the United States Court of Appeals for the Seventh Circuit reviewed only the class certification decision, focusing on predominance and superiority. The court affirmed the district court’s certification, holding that common questions about Amazon’s alleged statutory violations predominated and that individual questions regarding user location and damages were manageable. The court also agreed that a class action was superior to individual suits, given the complexity and cost of litigation, and affirmed the district court’s discretion. View "Svoboda v Amazon.com Inc." on Justia Law

Two individuals worked as delivery drivers for a transportation company for over a decade, primarily out of the company’s New Jersey terminal. Their work mainly involved picking up and delivering goods in New Jersey, with occasional deliveries in neighboring states. Each driver had a contract with the company that included a forum-selection clause requiring any disputes to be litigated in Memphis, Tennessee, and a choice-of-law clause providing that Tennessee law would govern any disputes. The company is incorporated in Delaware, headquartered in Illinois, and has operations nationwide, including in Tennessee, but neither the drivers nor the company’s relevant activities were based in Tennessee.The drivers filed a putative class action in the United States District Court for the District of New Jersey, alleging that the company violated New Jersey wage laws by withholding earnings and failing to pay overtime, among other claims. The case was transferred to the United States District Court for the Western District of Tennessee pursuant to the forum-selection clause. The company then moved to dismiss the complaint, arguing that the Tennessee choice-of-law provision applied and that Tennessee law did not recognize the claims brought under New Jersey statutes. The district court agreed, upheld the choice-of-law provision, and dismissed the case.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the enforceability of the choice-of-law provision under Tennessee’s choice-of-law rules. The court held that the contractual choice-of-law clause was unenforceable because there was no material connection between Tennessee and the transactions or parties. As a result, the Sixth Circuit reversed the district court’s dismissal and remanded the case for further proceedings. The court did not reach the question of whether Tennessee law was contrary to the fundamental policies of New Jersey. View "Andujar v. Hub Group Trucking, Inc." on Justia Law

A woman rented a car from a rental company in 2014 and, after a traffic camera recorded a violation during her rental, the company paid the fine and charged her both the fine amount and an administrative fee. She filed a putative class action in the United States District Court for the District of New Jersey on behalf of customers who were charged fines and fees in similar circumstances, alleging state-law claims such as violations of consumer fraud statutes and unjust enrichment. The rental company later updated its rental agreements in 2016 to include an arbitration clause and class-action waiver, but this provision applied only prospectively to rentals after its adoption. The named plaintiffs’ rentals predated this clause.The District Court, after years of litigation that included several amended complaints, discovery, mediation, and a motion to certify a class, ultimately certified a subclass that included some renters whose agreements contained the arbitration provision. The District Court found that the rental company had waived its right to enforce arbitration by participating in litigation for several years without moving to compel arbitration. The company then filed a motion to compel arbitration for the affected class members, which the District Court denied again on waiver grounds, emphasizing that the company had not sought to enforce arbitration until after class certification.On appeal, the United States Court of Appeals for the Third Circuit reviewed the waiver issue de novo. The Third Circuit held that waiver of the right to compel arbitration did not occur here, because the company’s conduct—such as raising arbitration as an affirmative defense and the futility of seeking to compel arbitration prior to class certification—did not evince an intentional relinquishment of that right. The Third Circuit vacated the District Court’s order denying the motion to compel arbitration and remanded for consideration of other unresolved questions about enforceability. View "Valli v. Avis Budget Group Inc" on Justia Law

Several participants in a terminated employee stock ownership plan asserted claims under the Employee Retirement Income Security Act (ERISA) following the sale and dissolution of their plan. The plan, created by A360, Inc. in 2016, purchased all company stock and became its sole owner. In 2019, A360 and its trustee sold the plan’s shares to another entity, amending the plan at the same time to include an arbitration clause that required all claims to be resolved individually and prohibited representative, class, or group relief. The plan was terminated shortly thereafter, and the proceeds were distributed to participants. The plaintiffs alleged that the defendants undervalued the shares and breached fiduciary duties, seeking plan-wide monetary and equitable relief.The United States District Court for the Northern District of Georgia considered the defendants’ motion to compel arbitration based on the plan’s amended arbitration provisions. The district court determined that although the plan itself could assent to arbitration, the arbitration provision was unenforceable because it precluded plan-wide relief authorized by ERISA. The court found that the provision constituted a prospective waiver of statutory rights and concluded that, per the plan amendment’s own terms, the arbitration provision was not severable and thus entirely void.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s denial of the motion to compel arbitration de novo. The Eleventh Circuit held that the arbitration provision was unenforceable under the effective vindication doctrine because it barred participants from seeking plan-wide relief for breaches of fiduciary duty, as provided by ERISA. The court joined other circuits in concluding that such provisions violate ERISA’s substantive rights and affirmed the district court’s invalidation of the arbitration procedure and denial of the motion to compel arbitration. View "Williams v. Shapiro" on Justia Law

A registered nurse who worked for the Indian Health Service during the COVID-19 pandemic claimed that she and similarly situated nurses were required by supervisors to work overtime without compensation. After resigning, she filed a class action lawsuit in the United States Court of Federal Claims, alleging, among other things, that the government violated the federal overtime statute by failing to pay for overtime that was allegedly induced by supervisors. Specifically, she argued that the statutory requirement for overtime to be “officially ordered or approved” should cover such induced overtime, even in the absence of written authorization.The United States Court of Federal Claims dismissed all counts of her complaint for failure to state a claim. With respect to the overtime claim (Count II), the court found that she did not allege that she or any potential class members had written authorization for their overtime, as required by the relevant Office of Personnel Management (OPM) regulation.On appeal, the United States Court of Appeals for the Federal Circuit, sitting en banc, reviewed the validity of the OPM’s regulation that requires overtime orders or approvals to be in writing, in light of the statutory language and recent Supreme Court precedent on agency rulemaking authority. The court held that the statute delegates to OPM the authority to prescribe necessary regulations for administering the overtime pay statute, and that this includes the discretion to require written authorization as part of the “officially ordered or approved” process. The court concluded that the writing requirement is a valid exercise of OPM’s rulemaking authority and does not contradict the statute. The Federal Circuit therefore affirmed the Court of Federal Claims’ dismissal of the overtime claim and remanded the remaining claims to the original panel for further consideration. View "Lesko v. United States" on Justia Law