Justia Class Action Opinion Summaries

Support staff who worked at a psychiatric hospital in Louisiana operated by Acadia-affiliated entities allege that, while they were provided with nominal meal breaks, they were functionally required to remain on call due to company policies and ethical obligations. As a result, they claim they were not properly compensated for this time. The plaintiffs, a former nurse supervisor and a former mental health technician, brought suit on behalf of themselves and similarly situated employees. Their claims included violations under the Fair Labor Standards Act (FLSA) and Louisiana state-law torts, specifically unjust enrichment and conversion.The United States District Court for the Eastern District of Louisiana certified both an FLSA collective action and a Rule 23(b)(3) class action for the state-law claims. Acadia sought interlocutory review of the class certification under Federal Rule of Civil Procedure 23(f). The Fifth Circuit Court of Appeals was presented with Acadia’s appeal challenging both the collective and class certification decisions.The United States Court of Appeals for the Fifth Circuit determined that it lacked jurisdiction to review the FLSA collective action certification at this stage, as Rule 23(f) provides for interlocutory review only of class certification orders, not collective actions. The court declined Acadia’s request to exercise pendent appellate jurisdiction because the legal standards and issues between the FLSA collective and the Rule 23 class were not sufficiently intertwined. Turning to class certification, the Fifth Circuit found no abuse of discretion by the district court. It held that the Rule 23 requirements of numerosity, commonality, typicality, adequacy, predominance, and superiority were satisfied based on the plaintiffs’ “on-call” theory, which presented common questions suitable for classwide adjudication. The court therefore affirmed the district court’s certification of the Rule 23 class, dismissed the appeal regarding the collective action, and remanded for further proceedings. View "Hamm v. Ochsner-Acadia" on Justia Law

A real estate investment trust issued shares governed by corporate charter documents that initially paid fixed dividends but were set to convert to floating rates tied to the London Inter-Bank Offered Rate (LIBOR). The charter provided three fallback options if LIBOR became unavailable. When LIBOR was discontinued, the company determined that the third fallback provision—a fixed rate based on the most recent dividend period—would apply. This decision was announced before the shares were set to convert to floating rates, leading to a decrease in the shares' market value.A shareholder filed a class action in the United States District Court for the Central District of California, alleging that the company’s failure to convert to SOFR-based floating rates, as selected by the Federal Reserve under the Adjustable Interest Rate (LIBOR) Act, violated California’s Unfair Competition Law (UCL). The shareholder claimed that a fixed rate could not serve as a valid “benchmark replacement” under the LIBOR Act. The company moved to dismiss, arguing that the fallback provision was a valid benchmark replacement, thus precluding a UCL claim. The district court denied the motion, finding ambiguity in the statute and relying on legislative history suggesting concern over fixed-rate conversions.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s order. The Ninth Circuit held that, under the plain text of the LIBOR Act, a “benchmark replacement” may include a fixed dividend rate as provided in the fallback provision, and there is no requirement that it be a floating rate. The court found the fallback provision to be a valid benchmark replacement and concluded that the company’s actions were not “unlawful” or “unfair” under the UCL. The case was remanded for further proceedings on any remaining issues. View "VERTHELYI V. PENNYMAC MORTGAGE INVESTMENT TRUST" on Justia Law

A group of Missouri home sellers brought a class action lawsuit in federal court, alleging that the National Association of Realtors (NAR) and several large real estate brokerage firms conspired to inflate buyer-broker commissions through a rule requiring sellers to offer compensation to buyers’ brokers via Multiple Listing Services (MLSs). The plaintiffs claimed this arrangement artificially increased transaction costs for sellers and buyers nationwide due to NAR’s market dominance. The class was initially limited to Missouri, Illinois, and Kansas home sellers using certain MLSs.After a trial in the United States District Court for the Western District of Missouri, a jury found the defendants liable for violating antitrust laws and awarded significant damages. While post-trial motions were pending, similar lawsuits emerged across the country. The parties began global settlement negotiations addressing claims from related cases, including those involving different MLSs and trade associations, such as the Real Estate Board of New York (REBNY). The settlement required NAR and others to pay over $1 billion and implement practice changes, including eliminating the contested rule. The settlement class expanded to nearly all U.S. home sellers using any MLS from 2014 to 2024. Following extensive notice and a fairness hearing, the district court certified the nationwide class, approved the settlement as fair under Federal Rule of Civil Procedure 23, and addressed all objections, including those from non-appearing objectors.On appeal, several objectors and interested parties challenged the settlement, raising issues about class scope, adequacy, fairness, the inclusion of unrelated claims, attorneys’ fees, due process, and the fairness hearing procedures. The United States Court of Appeals for the Eighth Circuit reviewed for abuse of discretion and found that the district court properly applied the relevant legal standards, including Rule 23(e). The Eighth Circuit affirmed the district court’s approval of the nationwide class-action settlement, holding that it was fair, reasonable, and adequate, and that the process satisfied constitutional and procedural requirements. View "Burnett v. Spring Way Center, LLC" on Justia Law

The plaintiff received two pre-recorded telemarketing calls from a vacation property company, which he alleged were made without his consent in violation of the Telephone Consumer Protection Act. The company had used third-party vendors to conduct a large-scale telemarketing campaign, targeting individuals whose phone numbers had been obtained from opt-in websites. The plaintiff, on behalf of himself and a proposed class, filed suit against the company in April 2019, asserting that these calls violated federal law.In the United States District Court for the Northern District of Illinois, the defendant engaged in extensive litigation over the course of four years. It filed answers with affirmative defenses, participated in class-related discovery, and litigated several motions, including opposing class certification and filing for summary judgment. Notably, the defendant did not assert arbitration as a defense until after the class was certified and significant litigation had occurred. When it finally raised arbitration—claiming that many class members had agreed to arbitrate through opt-in websites—the district court refused to allow the late amendment to add this defense, finding that it was too late and that the right to arbitrate had been waived. The district court later denied the defendant’s motion to compel arbitration, granted summary judgment to the plaintiff and the class, and ordered further settlement negotiations.Upon appeal, the United States Court of Appeals for the Seventh Circuit clarified the appropriate standard of review for orders denying motions to compel arbitration, holding that legal rulings with precedential effect are reviewed de novo, while the ultimate waiver determination is reviewed for clear error. The court further held that a defendant’s conduct prior to class certification is relevant in assessing waiver of the right to arbitrate. Finding no clear error in the district court’s conclusion that the defendant waived its arbitration rights by failing to timely assert them, the Seventh Circuit affirmed the judgment. View "Moore v Club Exploria, LLC" on Justia Law

In September 2024, a major fire at the Bio-Lab chemical facility in Rockdale County, Georgia, caused the release of a toxic chemical plume, resulting in an evacuation order for over 17,000 nearby residents. Many local residents subsequently sought medical attention for symptoms related to exposure to hazardous substances, including hydrogen cyanide. A group of affected residents and businesses filed a putative class action in the United States District Court for the Northern District of Georgia against Bio-Lab and related entities, alleging negligence, trespass, nuisance, and strict liability. However, the plaintiffs did not claim present physical injury; instead, they asserted an increased risk of future disease and sought, among other remedies, an injunction requiring the creation of a defendant-funded medical monitoring program.The defendants moved to dismiss the request for equitable relief, arguing that Georgia law does not permit medical monitoring as a remedy absent allegations of present physical injury. The federal district court, finding Georgia law unclear on this issue, certified two questions to the Supreme Court of Georgia: whether a plaintiff exposed to toxic substances without present physical injury may obtain equitable relief in the form of medical monitoring, and if so, what standard applies.The Supreme Court of Georgia responded that, under Georgia law, the availability of equitable relief depends on whether the plaintiff has suffered a legally cognizable injury and whether that injury meets the established criteria for equitable relief, including the absence of an adequate remedy at law and the imminence of harm. The court declined to decide whether the specific facts of this case warranted such relief, leaving that determination to the district court. Additionally, the court concluded that the precise form and scope of equitable relief in a federal diversity case is likely governed by federal law, not state law. The certified questions were thus answered only in part. View "BIO-LAB, INC. v. TARTT" on Justia Law

An employee of Royal Caribbean participated in the company’s retirement plan and invested in a series of target date funds managed by Russell. She, on behalf of a class, alleged that Royal Caribbean, as plan sponsor and fiduciary under ERISA, breached its duty of prudence by selecting and retaining the Russell Target Date Funds (TDFs) instead of alternatives like those from Vanguard or American Funds. The complaint highlighted that the Russell TDFs underperformed their peers and benchmarks, charged higher fees, and had features—such as a particular glidepath and asset allocation—that allegedly made them a poor fit for plan participants. Internal communications from Russell and Royal Caribbean raised concerns about the performance and cost of the Russell TDFs.The United States District Court for the Southern District of Florida granted summary judgment to Royal Caribbean. It reasoned that, in order to prove the investment was objectively imprudent, the plaintiff was required to present “apples-to-apples” comparator evidence—showing the Russell TDFs were worse than another fund with the same investment strategy and risk profile. The district court found that the plaintiff’s comparators, such as the Vanguard and American Funds TDFs, were not proper because they differed in strategy and structure from the Russell funds.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that an ERISA plaintiff is not always required to provide an “apples-to-apples” comparator to establish that an investment was objectively imprudent. The court explained that evidence of objective imprudence can be qualitative or quantitative, and the inquiry is context-specific, depending on all relevant facts and circumstances. The Eleventh Circuit reversed the district court’s grant of summary judgment and remanded the case for further proceedings. View "Johnson v. Russell Investments Trust Company" on Justia Law

Two consumers filed a lawsuit against a company that produces and sells eggs, challenging the company’s marketing claims that its hens are “free range” and “pasture raised on over 8 acres.” The plaintiffs alleged that these statements were deceptive because, in their view, the terms “pasture raised” and “free range” have objective meanings set by specific animal welfare certification organizations, and that consumers would expect the eggs to meet those standards. The plaintiffs sought to certify classes of California and New York consumers who purchased the eggs, arguing that the company’s advertising led consumers to pay a premium under false pretenses.The United States District Court for the Northern District of California considered the plaintiffs’ motion for class certification. During this process, the court excluded the plaintiffs’ expert’s opinion on the meaning of “pasture raised,” finding the expert’s methodology unreliable under Daubert v. Merrell Dow Pharmaceuticals, Inc. Without this expert opinion, the district court concluded that the plaintiffs could not show that deception was a common issue capable of classwide resolution, as required for predominance under Federal Rule of Civil Procedure 23(b)(3). Nonetheless, the court certified the classes, reasoning that common questions remained regarding the materiality of the statements and the calculation of damages.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s order granting class certification. The Ninth Circuit held that, in the absence of admissible expert evidence regarding what consumers understand “pasture raised” to mean, the plaintiffs failed to show that common issues of deception predominated. The court further held that common questions of materiality and damages could not, by themselves, justify class certification when the element of deception was not established on a classwide basis. View "RUSOFF V. THE HAPPY GROUP, INC." on Justia Law

An aluminum company had, through various collective bargaining agreements (CBAs), promised certain healthcare benefits to retirees, their spouses, and dependents. The agreements did not specify the duration of these benefits, but the company had been providing lifetime healthcare coverage to individuals who retired before June 1, 1993. In August 2020, the company announced it would transition these pre-1993 retirees to a new health reimbursement arrangement starting January 1, 2021, under which the company reserved the right to terminate benefits at any time. Over 3,000 affected individuals, including the widow of a former employee, challenged this change, alleging that it breached the CBAs and violated federal labor and benefits laws.The United States District Court for the Southern District of Indiana certified a class of affected retirees and their eligible spouses and dependents. After discovery, the court granted summary judgment as to liability in favor of the plaintiffs, relying on judicial estoppel. The court found that the company was barred from arguing that benefits were not vested for life because it had previously taken the opposite position in earlier litigation. As a result, the district court declared that class members were entitled to lifetime healthcare benefits and issued a permanent injunction requiring reinstatement of the prior plan and allowing claims for expenses incurred since January 1, 2021.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s certification of the class under Rule 23(b)(2), finding no abuse of discretion. However, it reversed the grant of summary judgment as to liability. The appellate court concluded that judicial estoppel did not apply because the company’s prior statements in earlier litigation were not clearly inconsistent with its current position. The case was remanded for further proceedings on the merits. View "Kaiser v Alcoa USA Corp." on Justia Law

The plaintiffs, who purchased securities issued by an animal health company, brought a proposed class action against the company and certain officers and directors. They alleged that the company misled investors by publicly attributing its sales growth to strong end-user demand, when in reality, the growth was artificially created through “channel stuffing”—the practice of pushing excessive inventory onto distributors, thus inflating reported revenues. The company’s alleged conduct took place around the time of major acquisitions and included public statements and SEC filings that, according to the plaintiffs, failed to disclose the channel stuffing and misrepresented the true basis for revenue increases.The United States District Court for the Southern District of Indiana reviewed the plaintiffs’ first amended complaint and dismissed it without prejudice for failure to state a claim, allowing an opportunity to amend. The plaintiffs sought to file a second amended complaint, asserting claims under the Securities Exchange Act of 1934 and the Securities Act of 1933, as well as related “control person” liability provisions. The district court denied leave to amend, deeming further amendment futile, and dismissed the case with prejudice. The court concluded the plaintiffs had not adequately alleged actionable misstatements, scienter (intent to defraud), or loss causation under the heightened pleading standards required by the Private Securities Litigation Reform Act and Federal Rule of Civil Procedure 9(b).On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The appellate court held that, even assuming the statements at issue could be considered materially misleading, the plaintiffs failed to allege facts giving rise to a strong inference of scienter. The court also agreed that the claims under the Securities Act sounded in fraud and therefore required particularized pleading, which the plaintiffs had not met. Consequently, all claims were properly dismissed with prejudice. View "Hunter v Elanco Animal Health Incorporated" on Justia Law

A Salvadoran national entered the United States without inspection in 2013 and lived in Massachusetts. In September 2025, he was arrested by immigration authorities during a vehicle stop and placed in removal proceedings, charged as inadmissible for being present without admission or valid documentation. Under longstanding practice, individuals in his situation could seek release from detention on bond while their removal cases were pending. However, in July 2025, the Department of Homeland Security issued guidance, later adopted by the Board of Immigration Appeals in Matter of Yajure Hurtado, that mandatory detention without bond applied to all noncitizens present in the U.S. without admission, shifting the legal framework and increasing the detained population.After his arrest, the individual challenged his detention without a bond hearing by filing a habeas petition in the United States District Court for the District of Massachusetts. The district court issued a preliminary injunction, requiring his release or a bond hearing, and later certified a class action for similarly situated noncitizens. The district court ultimately held that the new DHS policy violated the Immigration and Nationality Act (INA), finding that those present in the United States without admission were entitled to bond hearings under 8 U.S.C. § 1226(a), not subject to mandatory detention under § 1225(b)(2)(A).On appeal, the United States Court of Appeals for the First Circuit reviewed whether the INA requires mandatory detention without bond for noncitizens present in the country without admission, or if they are eligible for bond hearings. The First Circuit held that § 1225(b)(2)(A) applies only to noncitizens "seeking admission"—that is, those seeking lawful entry at the border—not those already present after unlawful entry. Accordingly, detention and bond eligibility for class members are governed by § 1226(a), not § 1225(b)(2)(A), and the district court’s order was affirmed. View "Guerrero Orellana v. Moniz" on Justia Law