Justia Class Action Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals affirming a modified version of the order of the district court certifying a class, holding that when the claims for which the plaintiffs seek class certification have no basis in law, even taking all the allegations as true, class certification cannot be granted.Tenants sued Landlord alleging a violation of Tex. Prop. Code 92.056(g), arguing that Landlord was strictly liable for omitting a required lease term. Tenants sought class certification of a class of more than 65,000 former tenants. Landlord moved for summary judgment, arguing that the lawsuit amounted to an "ineffectual[] attempt to manufacture strict-liability requirements and civil-penalty remedies that do not exist under a plain reading of the Texas Property Code." The district court granted the motion for class certification, and the court of appeals affirmed as modified. The Supreme Court reversed, holding that where Tenants' proposed class claims had no basis law, the "rigorous analysis" necessary to certify the class could not meaningfully be performed. View "American Campus Communities, Inc. v. Berry" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the trial court's order certifying a class in this action claiming violations of Tex. Prop. Code 92.019, which regulates landlords' ability to impose late fees on tenants who untimely pay their rent, holding that the trial court abused its discretion by failing to address Petitioners' defenses in the trial plan and their effects on the requirement for class certification.Respondent sued Petitioners for breach of Tex. Prop. Code 92.019 for charging and collecting late fees and charging back rent concessions. Respondent later moved for class certification. After a hearing, the trial court granted the motion. The court of appeals affirmed. The Supreme Court reversed, holding that the trial court abused its discretion by failing correctly to identify the elements of Petitioners' defenses in the trial plan and address their effect on the requirements for class certification in violation of Tex. R. Civ. P. 42(c)(1)(D). View "Mosaic Baybrook Once, L.P. v. Cessor" on Justia Law

In this dispute over a "Water/Sewer Base Fee" that Landlords billed tenants each month to recover certain amounts it had paid the municipal utility district the Supreme Court affirmed the trial court's grant of partial summary judgment in Tenant's favor and the court of appeals' judgment affirming the trial court's order certifying a class under Rule 24 of the Texas Rules of Civil Procedure, holding that there was no error.Tenant brought suit against Landlords challenging a fee that included not only each apartment's allocated portion of the utility's customer service charge for water and sewer service but also an undisclosed amount equivalent to a portion of the utility's charges for non-water emergency services. Tenant sued under the Water Code on behalf of a tenant class. The trial court granted Landlords' motion for partial summary judgment on liability and certified a class. The Supreme Court affirmed, holding that the trial court (1) did not err in granting partial summary judgment; and (2) did not abuse its discretion in certifying the class. View "Mosaic Baybrook One, L.P. v. Simien" on Justia Law

Adams and Mounts mined coal in Kentucky. Both wore respirators to protect their lungs but nevertheless developed pneumoconiosis, a disease caused by inhaled dust particles. They sued 3M and other out-of-state respirator manufacturers and distributors. Adams’ complaint named more than 400 co-plaintiffs. Mounts’ complaint named more than 300 co-plaintiffs. 3M removed the cases to federal court. The district court remanded to state court.On interlocutory appeal, the Sixth Circuit reversed the remand order. The 2005 Class Action Fairness Act (CAFA) extends federal diversity jurisdiction to certain “mass action[s]” involving “100 or more persons,” 28 U.S.C. 1332(d)(11)(B)(i) and permits removal of any civil action “in which monetary relief claims of 100 or more persons are proposed to be tried jointly on the ground that the plaintiffs’ claims involve common questions of law or fact.” These complaints did that. Claims presented in a single complaint proceed through a common trial process absent an order to the contrary; when the plaintiffs each filed complaints with more than 100 co-plaintiffs, they offered to try their co-plaintiffs’ claims jointly. Both complaints sought “a trial by jury” and a singular “judgment,” not multiple trials and judgments. By filing a complaint predicated on a “common” “question of law or fact,” the plaintiffs offered the presence of common questions as a “ground” for pursuing a joint trial, View "Adams v. 3M Co." on Justia Law

Plaintiff sought to represent a class of individuals, known as Amazon Flex drivers, claiming damages and injunctive relief for alleged privacy violations by Amazon.com, Inc. (“Amazon”). Plaintiff contended that Amazon monitored and wiretapped the drivers’ conversations when they communicated during off hours in closed Facebook groups. The district court denied Amazon’s motion to compel arbitration, holding that the dispute did not fall within the scope of the applicable arbitration clause in a 2016 Terms of Service Agreement (“2016 TOS”). Amazon appealed, arguing that the district court should have applied the broader arbitration clause in a 2019 Terms of Service Agreement (“2019 TOS”) and that even if the arbitration clause in the 2016 TOS applied, this dispute fell within its scope.   The Ninth Circuit affirmed the district court’s order denying Amazon’s motion to compel arbitration. Under California law and principles of contract law, the burden is on Amazon, as the party seeking arbitration, to show that it provided notice of a new TOS and that there was mutual assent to the contractual agreement to arbitrate. The panel held that there was no evidence that the email allegedly sent to drivers adequately notified drivers of the update. The district court, therefore, correctly held that the arbitration provision in the 2016 TOS still governed the parties’ relationship. The panel concluded that because Amazon’s alleged misconduct existed independently of the contract and therefore fell outside the scope of the arbitration provision in the 2016 TOS, the district court correctly denied Amazon’s motion to compel arbitration. View "DRICKEY JACKSON V. AMZN" on Justia Law

Plaintiff, MSP Recovery Claims, Series LLC (“MSP”) appealed from the district court’s judgment dismissing for lack of standing its putative class action against Defendant Hereford Insurance Company (“Hereford”) and denying leave to amend. MSP has brought several lawsuits around the country seeking to recover from insurance companies that allegedly owe payments to Medicare Advantage Organizations (“MAOs”) under the Medicare Secondary Payer Act (the “MSP Act”). In the putative class action brought here, MSP charges Hereford with “deliberate and systematic avoidance” of Hereford’s reimbursement obligations under the MSP Act.   The Second Circuit affirmed. The court concluded that MSP lacked standing because its allegations do not support an inference that it has suffered a cognizable injury or that the injury it claims is traceable to Hereford. The court also concluded that the district court did not abuse its discretion when it denied MSP leave to amend based on MSP’s repeated failures to cure. The court explained that the plain language of Section 111 provides that when a no-fault insurance provider such as Hereford reports a claim pursuant to Section 111, it does not thereby admit that it is liable for the claim. The statutory context of the section’s reporting obligation and the purpose of the reporting obligation confirms the correctness of this interpretation. Because MSP’s argument that the payments made by EmblemHealth are reimbursable by Hereford rests entirely on its proposed interpretation of Section 111, MSP has not adequately alleged a “concrete” or “actual” injury or that the injury it alleges is fairly traceable to Hereford. View "MSP v. Hereford" on Justia Law

The Butter! Spray is a butter-flavored vegetable oil dispensed in pump-action squirt bottles with a spray mechanism. The front label on the product states that the Butter! Spray has 0 calories and 0 grams of fat per serving. Plaintiffs are a class of consumers who brought their lawsuit against the then-manufacturer, Unilever United States, Inc., contending that the product’s label makes misrepresentations about fat and calorie content based on artificially low serving sizes. The district court found that Plaintiffs failed to plausibly allege that Butter! Spray was not a “spray type” fat or oil under Food and Drug Administration (FDA) regulations. The district court further held that the FDCA preempted plaintiffs’ serving size claims.   The Ninth Circuit affirmed the district court’s Fed. R. Civ. P. 12(b)(6) dismissal. The panel held that, as a matter of legal classification, Butter! Spray was a “spray.” In common parlance, a “spray” refers to liquid dispensed in the form of droplets, emitted from a mechanism that allows the product to be applied in that manner. In addition, the notion that Butter! Spray could be housed under the FDA’s legal classification for “butter” is implausible. The panel also rejected Plaintiffs’ argument that Butter! Spray is a “butter substitute” based on how it is marketed so it should be treated as “butter” for serving size purposes, too. The court explained that because Plaintiffs’ challenge to the Butter! Spray serving sizes would “directly or indirectly establish” a requirement for food labeling that is “not identical” to federal requirements, the FDCA preempts their serving size claims. View "KYM PARDINI, ET AL V. UNILEVER UNITED STATES, INC." on Justia Law

AMA Capital, LLC (“AMA”) is a claimant in an antitrust class-action settlement. The settlement agreement at issue required that each claimant substantiate its claims with such documents as class counsel and the claims administrator, in their discretion, deemed acceptable. The settlement agreement also provided each claimant with the opportunity to (1) remedy deficiencies in its claims before the claims administrator issued its decision and (2) if the claims administrator rejected its claims in whole or in part, contest the claims administrator’s decision within twenty days of the mailing of the rejection notice. In this case, the claims administrator rejected most of AMA’s claims because, among other things, AMA repeatedly failed to provide the requisite transactional records to support its claims. The district court agreed and also denied AMA’s motion for reconsideration based on documents it submitted subsequent to the claims administrator’s rejection.   On appeal, AMA argues primarily that the district court erred by failing to consider documents it submitted during the post-rejection contest process and by denying its claims on the basis of improper evidentiary requirements. The Second Circuit affirmed the district court’s order holding that the claims administrator was not required to accept records during the contest process that were previously available to AMA, which is akin to a motion for reconsideration, and that the district court did not err by denying AMA’s claims. Moreover, because AMA has standing as a class member to appeal any denial of its claims, the court dismissed as moot the appeal in No. 22-19, which challenges the district court’s denial of AMA’s motion to intervene. View "Contant v. AMA Cap., LLC" on Justia Law

The Supreme Court affirmed the judgment of the district court refusing to certify Appellant's case as a class action, holding that, based on the facts and circumstances of this case, the district court did not abuse its broad discretion.Appellant, a horse breeder and owner, brought this putative class action claiming that Prairie Meadows Racetrack and Casino, Inc. breached contracts governing the distribution of winnings among owners and breeders of successful horses. The district court ultimately denied certification. The Supreme Court affirmed, holding that there was no abuse of discretion in the district court's determination that Appellant was not an appropriate class representative and that certification was inappropriate. View "Benda v. Prairie Meadows Racetrack & Casino Inc." on Justia Law

This is an appeal from a district court order approving a class-action settlement that purports to provide injunctive relief and up to $8 million in monetary relief to a class of individuals (the “Class”) who purchased one or more “brain performance supplements” manufactured and sold by Defendants Reckitt Benckiser LLC and RB Health (US) LLC (together, “RB”) under the brand name “Neuriva.” Five Plaintiffs (together, the “Named Plaintiffs”) who had previously purchased Neuriva brought a putative class action, alleging that RB used false and misleading statements to give consumers the impression that Neuriva and its “active ingredients” had been clinically tested and proven to improve brain function. The parties promptly agreed to a global settlement (the “Settlement” or “Settlement Agreement”) that sought to resolve the claims of all Plaintiffs and absent Class members. The current appeal involves one unnamed Class member, an attorney and frequent class-action objector, who objected in district court and subsequently appealed the district court’s approval order.   The Eleventh Circuit vacated the district court’s order and remanded. The court concluded that the Named Plaintiffs lack standing to pursue their claims for injunctive relief. The court explained that Plaintiffs seeking injunctive relief must establish that they are likely to suffer an injury that is “actual or imminent,” not “conjectural or hypothetical.” But none of the Named Plaintiffs allege that they plan to purchase any of the Neuriva Products again. The district court, therefore, lacked jurisdiction to award injunctive relief to the Named Plaintiffs or absent Class members, and its approval of the Settlement Agreement was an abuse of discretion. View "David Williams, et al v. Reckitt Benckiser LLC, et al" on Justia Law