Justia Class Action Opinion Summaries

A developer challenged the legality of “recreation fees” imposed by a municipality on builders of new subdivisions. The developer argued that the town’s fees, charged in lieu of dedicating land for public recreation, either exceeded statutory limits or were unconstitutional because they were not proportionate to each development’s impact. The developer further alleged that the municipality did not use the fees as required, instead commingling them with general funds and failing to create or improve public recreation areas near the developments.In the Superior Court of Wake County, the developer pursued a putative class action seeking declaratory relief and a refund of all such fees paid since November 2017. The Superior Court certified a class including all payers of the recreation fees, finding several common legal questions appropriate for resolution on a class-wide basis. These included whether the fees violated statutory requirements, whether their calculation was legally proper, whether their use complied with statutory mandates, and whether they were constitutionally proportionate. The municipality appealed directly to the Supreme Court of North Carolina, arguing that individualized factual inquiries predominated over common issues and that a class action was not the superior method of adjudication.The Supreme Court of North Carolina held that the class as certified did not satisfy the predominance requirement for class actions. The Court explained that several claims—such as whether fees exceeded fair market value or were roughly proportional—would require individualized, fact-intensive determinations for each class member, resulting in mini-trials that would overwhelm the common legal issues. Consequently, the Supreme Court vacated the trial court’s class certification order and remanded for further proceedings, instructing the lower court to reconsider class certification in light of these findings. View "Empire Contractors Inc. v. Town of Apex" on Justia Law

Plaintiff brought suit on behalf of her minor children and a proposed class of individuals who were exposed to polychlorinated biphenyls (PCBs) while attending or working at certain Vermont public schools. The complaint alleged that defendants, as successors to Old Monsanto, manufactured and sold PCBs from facilities outside Vermont to third-party manufacturers, who incorporated PCBs into products such as fluorescent light ballasts and caulk. These products were later used in Vermont schools, where PCBs subsequently leaked into the air, allegedly resulting in toxic exposure.In the United States District Court for the District of Vermont, defendants moved to dismiss the complaint, arguing that Vermont’s medical-monitoring statute only applied to releases of toxic substances directly from facilities located within Vermont, and did not apply retroactively to exposures or sales occurring prior to the statute’s enactment in 2022. The District Court certified two questions to the Vermont Supreme Court for interpretation of the statute.The Vermont Supreme Court reviewed the certified questions. The Court held, first, that the sale of a toxic substance from facilities outside Vermont, which was then incorporated into products that leaked PCBs into the air of Vermont schools, qualified as a “release” within the meaning of Vermont’s medical-monitoring statute. Second, the Court held that the statute does not provide a remedy to plaintiffs whose exposure occurred before the statute’s enactment, but it does allow claims against defendants who sold a toxic substance before enactment, if the plaintiff’s exposure occurred after July 1, 2022. The Court provided these answers in response to the certified questions and clarified the scope and retroactivity of the statute. View "Neddo, as Guardian & Next Friend to Z.N." on Justia Law

Plaintiffs filed a class action against the Department of Homeland Security and Immigration and Customs Enforcement, alleging that the agencies were arresting noncitizens without a warrant in violation of 8 U.S.C. § 1357(a)(2). After years of litigation, the parties entered into a Consent Decree in 2021, approved by the United States District Court for the Northern District of Illinois in 2022. The Decree required the agencies to issue a policy statement, train officers, and document compliance with § 1357(a)(2). It also outlined procedures for enforcement and modification if violations were alleged.Prior to the Decree’s scheduled expiration in May 2025, Plaintiffs moved to enforce its terms and to extend its duration, asserting substantial noncompliance by Defendants. While these motions were pending, a DHS official declared the Decree terminated. On October 7, 2025, the district court found Defendants had violated the Decree, extended its term by 118 days, and ordered compliance-related relief. Later, Plaintiffs sought release or alternative detention for hundreds of individuals allegedly arrested in violation of the Decree. On November 13, 2025, the district court ordered the release of 13 individuals whom both parties agreed were arrested unlawfully, and additionally ordered release or alternatives for approximately 442 “potential class members,” pending determinations of violation.The United States Court of Appeals for the Seventh Circuit reviewed Defendants’ emergency motion to stay the district court’s October 7 and November 13 orders. The Seventh Circuit denied the request to stay the extension of the Consent Decree, holding that Defendants were unlikely to succeed on the merits of their argument that the extension violated 8 U.S.C. § 1252(f)(1). However, the court granted the stay as to the November 13 release order for those arrested pursuant to I-200 warrants and for “potential class members” pending individualized determinations under the Decree. The ruling sets forth the standards for stays and clarifies the limitations of § 1252(f)(1) in the context of class-wide injunctive relief and consent decree enforcement. View "Castanon Nava v. Department of Homeland Security" on Justia Law

The plaintiff, who worked as a truck driver for the defendants for approximately nine months in 2018, brought claims alleging that the defendants failed to provide required meal and rest breaks, failed to reimburse necessary work-related expenses, and violated California’s unfair competition law. The plaintiff also filed a representative claim for civil penalties under the Labor Code Private Attorneys General Act of 2004 (PAGA), all arising from his employment as a driver.The Superior Court of Sutter County denied the plaintiff’s motion for class certification on the meal break, rest break, expense reimbursement, and unfair competition claims. In particular, the court found that the plaintiff failed to present substantial evidence of a common policy of discouraging breaks or of a community of interest among the proposed class members. The court relied on declarations from other drivers indicating they were not discouraged from taking breaks and noting variability in their experiences. The court also granted the defendants’ motion to strike the PAGA claim on manageability grounds, reasoning that adjudicating the claim would require individual testimony from 75 drivers and would be unmanageable.The California Court of Appeal, Third Appellate District, affirmed in part and reversed in part. It affirmed the denial of class certification for the rest break and expense reimbursement claims, finding insufficient evidence of commonality. However, it reversed the denial of class certification for the meal break and derivative unfair competition claims, holding that the trial court failed to apply the burden-shifting framework required by Donohue v. AMN Services, LLC when time records show missed or unrecorded meal breaks. Additionally, the appellate court reversed the order striking the PAGA claim, holding that trial courts lack inherent authority to strike PAGA claims solely based on manageability concerns, as clarified in Estrada v. Royalty Carpet Mills, Inc. The case was remanded for further proceedings, including consideration of whether the PAGA claim is preempted by federal law. View "Dieves v. Butte Sand Trucking Co." on Justia Law

A former hourly employee brought a class action lawsuit against his former employer, a large wood products company, alleging various wage and hour violations under California law. The proposed classes included both employees who had signed arbitration agreements and those who had not. While some nonexempt employees had signed arbitration agreements requiring individual arbitration and waiving class actions, the named plaintiffs had not. The employer did not initially assert arbitration as a defense and, when ordered by the court to produce copies of signed arbitration agreements for putative class members, failed to do so for several years.During the course of discovery in the Superior Court of Shasta County, the employer repeatedly resisted requests to identify or produce arbitration agreements for employees who had signed them, leading to multiple discovery sanctions. The employer participated in extensive discovery and mediation involving employees who had signed arbitration agreements, without distinguishing them from other putative class members. Only after class certification did the employer finally produce thousands of signed arbitration agreements and immediately moved to compel arbitration for those employees. Plaintiffs opposed, arguing the employer had waived its right to arbitrate by years of litigation conduct inconsistent with an intent to arbitrate, and sought evidentiary and issue sanctions for delayed production.The California Court of Appeal, Third Appellate District, reviewed the case. Applying the California Supreme Court’s standard from Quach v. California Commerce Club, Inc., the appellate court held that the employer waived its right to compel arbitration by clear and convincing evidence. The employer’s prolonged failure to produce arbitration agreements and its conduct throughout litigation was inconsistent with an intention to enforce arbitration. The order denying the motion to compel arbitration was affirmed, and the appeal from the order granting evidentiary and issue sanctions was dismissed as nonappealable. View "Sierra Pacific Industries Wage and Hour Cases" on Justia Law

Several parents of disabled children brought a class action against the New York City Department of Education, the Board of Education of the City School District of New York, and the Chancellor, alleging that the defendants violated the Individuals with Disabilities Education Act (IDEA). The plaintiffs claimed the defendants maintained a policy of discontinuing special education services to disabled students before their twenty-second birthday, despite federal and state guidance and previous case law indicating that such services should continue until that age.The United States District Court for the Southern District of New York dismissed the suit, finding that it lacked subject-matter jurisdiction because the plaintiffs had not exhausted administrative remedies as generally required under the IDEA. The district court agreed with the defendants’ argument that exhaustion was necessary and rejected the plaintiffs’ contention that exhaustion would be futile due to the existence of a blanket, citywide policy.On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s dismissal. The appellate court clarified that the IDEA’s exhaustion requirement is not jurisdictional but is instead a claim-processing rule, meaning that failure to exhaust is not a bar to the court’s power to hear the case. The Second Circuit held that exhaustion of administrative remedies is excused when plaintiffs challenge a policy or practice of general applicability that is contrary to law and when the purposes of exhaustion—such as developing a factual record or utilizing agency expertise—would not be served. Because the plaintiffs’ claims raised a purely legal question regarding the validity of a blanket policy, the court found that exhaustion would be futile. The Second Circuit vacated the district court’s dismissal and remanded the case for further proceedings. View "J.M. v. New York City Dept. of Ed." on Justia Law

A company that provides temporary labor to various industries offers daily work opportunities to individuals at its labor halls. Workers can choose whether to accept job assignments, and once they do, they are responsible for arriving at the jobsite on time. The company offers several transportation options—including vans, carpools, and public transit—with a nominal fee deducted from paychecks for those who use company-arranged transportation. Workers can also bring their own tools or use company-provided equipment, with deductions only made for unreturned items.A group of workers filed a class action in the United States District Court for the Southern District of Florida, alleging violations of the Fair Labor Standards Act (FLSA) and the Florida Minimum Wage Act. They claimed that transportation deductions reduced their pay below the minimum wage and that the company failed to pay for travel time, time spent collecting tools, and waiting time. The plaintiffs also raised a claim under the Florida Labor Pool Act regarding excessive transportation charges. The district court granted summary judgment to the company on the FLSA and minimum wage claims, denied the plaintiffs’ summary judgment motion, and declined to certify the subclass related to excessive transportation charges.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the transportation deductions were lawful because the transportation was optional and for the benefit of employees, not the employer. The court further held that time spent traveling, collecting tools, and waiting was not integral and indispensable to the workers’ principal activities and was thus noncompensable under the FLSA. Finally, the court affirmed the district court’s denial of class certification for the excessive-transportation-charge subclass, finding that individual inquiries would predominate. The judgment of the district court was affirmed. View "Villarino v. Pacesetter Personnel Service, Inc." on Justia Law

The case concerns challenges to groundwater replenishment charges imposed by a water district in a desert region where groundwater is the main source of potable water. The water district operates three areas of benefit (AOBs) and levies replenishment charges on customers who pump significant groundwater. Domestic customers do not pay these charges directly, but their payments for drinking water are allocated to the replenishment funds through the district’s enterprise fund system. Plaintiffs, including a taxpayer association, alleged that the replenishment charges were unconstitutionally structured, resulting in higher rates for certain AOBs and unfair subsidies for others, benefitting large agricultural businesses.The litigation began with a combined petition and class action in the Superior Court of Riverside County, which was dismissed because the court found the validation statutes applied and the statute of limitations had expired. Subsequent reverse validation actions for later fiscal years were timely filed and consolidated. The Superior Court, in rulings by two judges, found the replenishment charges to be unconstitutional taxes because they did not satisfy the requirements of California Constitution Article XIII C, Section 1, subdivision (e)(2). Specifically, the court found that the district failed to show the allocation of replenishment costs bore a fair or reasonable relationship to the burdens or benefits received by each AOB, and thus the charges were not exempt from being classified as taxes. The court awarded substantial refunds to affected ratepayers and enjoined the district from imposing similar unconstitutional charges in the future.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed both the district’s appeal of the remedies and liability findings and the taxpayer association’s cross-appeal on procedural grounds. The appellate court affirmed in full, holding that the replenishment charges were unconstitutional, the remedies were proper, and that the validation statutes applied to these charges, thus barring untimely claims for earlier years. The appellate court also found no error in the trial court’s grant of refund and injunctive relief. View "Howard Jarvis Taxpayers Assn. v. Coachella Valley Water Dist." on Justia Law

A Missouri consumer purchased several containers of coffee that prominently displayed the number of servings each container could make. He claimed these representations were misleading, arguing that following the recommended single-serving brewing method would not produce as many servings as advertised. He filed a lawsuit against the coffee manufacturer and its parent company, alleging violations of the Missouri Merchandising Practices Act (MMPA) and unjust enrichment. The plaintiff sought to represent a class of Missouri consumers who purchased the same products.Multiple similar lawsuits from around the country were consolidated in the United States District Court for the Western District of Missouri. The district court appointed interim class counsel and, at the parties’ suggestion, considered whether to certify a Missouri class before addressing other states. The district court ultimately certified the Missouri class, finding that the plaintiff’s claims were suitable for class treatment under Federal Rule of Civil Procedure 23(b)(3), which requires that common questions predominate over individual ones.On appeal, the United States Court of Appeals for the Eighth Circuit held that the district court erred in certifying the class. The appellate court determined that individual questions about whether consumers saw, interpreted, or relied upon the product representations would predominate over common questions. The court rejected the plaintiff’s argument that all class members suffered harm due to alleged price inflation, reasoning that only those who were actually misled or cared about the representations could have incurred an ascertainable loss under the MMPA. The court also found the unjust enrichment claim similarly unsuited to class treatment because it would require individualized inquiries into whether each transaction was unjust. The Eighth Circuit reversed the class certification order and remanded the case for further proceedings. View "Sorin v. The Folger Coffee Company" on Justia Law

A freight train operated by Norfolk Southern derailed in East Palestine, Ohio, in early 2023, releasing hazardous materials and causing widespread evacuations and concern over health, environmental, and economic impacts. Numerous lawsuits were filed by affected individuals and businesses, which were consolidated into a master class action. The parties reached a $600 million settlement, which included provisions for a settlement fund and attorney’s fees. The district court approved the settlement and the attorney’s fees request, designating co-lead counsel to allocate fees among the plaintiffs’ attorneys, including Morgan & Morgan, a firm representing some individual claimants.After the district court in the United States District Court for the Northern District of Ohio approved the settlement and fee awards, Morgan & Morgan, despite having received nearly $8 million in fees, objected to the process and timing of fee allocation, specifically challenging the settlement’s “quick pay” provision and the authority given to co-lead class counsel to distribute fees. Morgan & Morgan also raised concerns about transparency and the adequacy of its own fee award, arguing that the allocation process might have undervalued its contributions.On appeal, the United States Court of Appeals for the Sixth Circuit held that Morgan & Morgan lacked standing to challenge the quick pay provision, as it did not suffer a concrete, particularized injury from the timing of payment and had assented to the settlement terms. The court also affirmed the district court’s decision to delegate initial fee allocation authority to co-lead class counsel, finding no abuse of discretion and noting the court retained jurisdiction for oversight. However, the Sixth Circuit found the district court had failed to address Morgan & Morgan’s specific concerns about its fee allocation and remanded that narrow issue for further consideration. The judgment was thus affirmed in part, reversed in part, and remanded. View "In re E. Palestine Train Derailment" on Justia Law