Justia Class Action Opinion Summaries

The City of Gridley operates an electric utility and approved reduced electric rates for residential users in September 2020. Plaintiffs, residential ratepayers, challenged these rates, alleging they resulted in charges exceeding the reasonable cost of providing electric service, thus constituting a tax without voter approval in violation of article XIII C of the California Constitution. They also claimed the rates violated the state and federal takings clauses under the unconstitutional conditions doctrine. Plaintiffs sought a writ of mandate and class action complaint, alleging the City set rates higher than necessary and transferred excess revenues to its general fund.The Superior Court of Butte County denied the City’s motion for summary judgment, finding triable issues of fact regarding whether the rates resulted in excessive charges and whether plaintiffs had a property interest in continued electric service. The court rejected the City’s argument that article XIII C was inapplicable because the City did not impose, extend, or increase a tax when it approved reduced rates. The court also found that the unconstitutional conditions doctrine could apply to plaintiffs' takings claim.The California Court of Appeal, Third Appellate District, reviewed the case and concluded that the City was entitled to relief. The court found article XIII C inapplicable because the City did not impose, extend, or increase any tax by reducing its electric rates. The court also found the unconstitutional conditions doctrine inapplicable, as it applies only in the land-use permitting context, not to user fees like the electric rates in question. Consequently, the court directed the trial court to set aside its order denying the City’s motion for summary judgment and to enter a new order granting the motion. The City’s motion for summary judgment was granted, and the stay of proceedings in the trial court was vacated. View "City of Gridley v. Super. Ct." on Justia Law

Dan Hamilton, an employee at an Amazon warehouse in Aurora, Colorado, received both holiday pay and holiday incentive pay. Holiday pay was his regular hourly rate for company holidays, regardless of whether he worked. Holiday incentive pay was one and one-half times his regular rate for hours worked on holidays. Hamilton filed a class action complaint alleging Amazon violated the Colorado Wage Act by not including holiday incentive pay in the calculation of his overtime pay.The case was initially filed in Arapahoe County District Court but was removed to the United States District Court for the District of Colorado. Amazon moved to dismiss the complaint, arguing that holiday incentive pay could be excluded from the regular rate of pay under both Colorado law and the Federal Fair Labor Standards Act (FLSA). The federal district court agreed with Amazon, ruling that Colorado law did not require the inclusion of holiday incentive pay in the regular rate of pay calculation, and dismissed Hamilton's complaint. Hamilton appealed to the Tenth Circuit, which then certified a question of law to the Supreme Court of Colorado.The Supreme Court of Colorado reviewed the certified question and concluded that holiday incentive pay must be included in the calculation of the regular rate of pay under Colorado law. The court found that the plain language of the relevant regulations, specifically 7 Colo. Code Regs. § 1103-1:1.8 and 1.8.1, mandated the inclusion of all compensation for hours worked, including holiday incentive pay. The court rejected Amazon's arguments that holiday incentive pay could be excluded and that Colorado law should be interpreted in line with the FLSA. The court held that holiday incentive pay is a form of shift differential and must be included in the regular rate of pay calculation. View "Hamilton v. Amazon.com Services" on Justia Law

The case involves a class action lawsuit against the City of Los Angeles, challenging the constitutionality of a $63 late fee imposed for failing to pay a parking meter fine within 21 days. The plaintiffs argue that this late fee, which matches the amount of the original fine, violates the Eighth Amendment's Excessive Fines Clause. The plaintiffs incurred at least one parking meter citation and late fee, and they assert that the late fee is both facially unconstitutional and unconstitutional as applied to individuals who cannot afford to pay it within the specified time frame.The United States District Court for the Central District of California initially granted summary judgment in favor of the City, finding that the $63 parking fine was not "grossly disproportionate" to the offense of overstaying a parking meter. The court also rejected the challenge to the $63 late fee without providing a detailed rationale. The plaintiffs appealed, and the Ninth Circuit previously upheld the initial fine but remanded the case to determine whether the late fee violated the Excessive Fines Clause.The United States Court of Appeals for the Ninth Circuit reversed the district court's summary judgment for the City regarding the late fee. The Ninth Circuit found that a genuine factual dispute exists about the City's basis for setting the late fee at 100 percent of the parking fine. The court noted that the City provided no evidence on how it determined the $63 late fee amount, making it impossible to conclude as a matter of law that the fee is not "grossly disproportional" to the harm caused by the untimely payment. The court declined to incorporate means-testing into the Excessive Fines Clause analysis, rejecting the plaintiffs' argument that the fee should consider individuals' ability to pay. The case was remanded for further proceedings consistent with this opinion. View "PIMENTEL V. CITY OF LOS ANGELES" on Justia Law

Adam and Miranda Steines, along with Andrew Ormesher, filed a class action lawsuit against Westgate, a resort company, alleging violations of the Military Lending Act (MLA). The Steines, who purchased a timeshare in Orlando and financed it through a loan from Westgate, claimed that Westgate's loan documents did not comply with the MLA's requirements, including the prohibition of mandatory arbitration clauses. The Steines sought rescission of their timeshare, injunctive relief, damages, and restitution.The United States District Court for the Middle District of Florida held an evidentiary hearing and denied Westgate's motions to compel arbitration and dismiss the complaint. The court found that the MLA applied to the timeshare loan and that the MLA's prohibition on mandatory arbitration clauses overrode the Federal Arbitration Act (FAA). Westgate appealed the decision, arguing that the district court should not have addressed the arbitrability issue and that the MLA did not override the FAA.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The court held that the question of whether the MLA overrides the FAA is a matter for the court to decide, not the arbitrator. The court found that the MLA explicitly prohibits mandatory arbitration clauses in consumer credit contracts involving servicemembers, thereby overriding the FAA. Additionally, the court agreed with the district court's finding that the timeshare loan did not qualify as a "residential mortgage" under the MLA, as the timeshare units were more akin to hotel rooms than residential dwellings.As a result, the Eleventh Circuit dismissed the interlocutory appeal for lack of jurisdiction, affirming that the MLA's provisions rendered the FAA inapplicable in this case. View "Steines v. Westgate Palace, L.L.C." on Justia Law

Two students receiving special education services filed a class action lawsuit against the Kanawha County Board of Education, alleging that the Board denied them and other similarly situated students a free appropriate public education (FAPE) as guaranteed by the Individuals with Disabilities Education Act (IDEA). The lawsuit also claimed violations of Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act. The district court certified a class of all Kanawha County Schools students with disabilities who need behavior supports and have experienced disciplinary removals from any classroom.The United States District Court for the Southern District of West Virginia granted the plaintiffs' motion to certify the class, reasoning that the plaintiffs had presented expert evidence of disproportionate rates of suspension for students with disabilities and a detailed qualitative analysis of student records. The court found that these factors revealed a cohesive pattern indicating the absence of an effective system for developing and implementing behavioral supports for students with disabilities. The Board appealed, arguing that the certification of the plaintiff class was inconsistent with Federal Rules of Civil Procedure 23(a) and (b)(2).The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court’s certification order. The Fourth Circuit held that the certified class failed to satisfy Rule 23(a)(2)’s commonality prerequisite. The court found that the plaintiffs did not identify a common contention central to the validity of all class members’ claims. The court noted that the claims were highly diverse and individualized, involving different practices at different stages of the special education process. The absence of a common contention foreclosed class treatment. The case was remanded for further proceedings consistent with the opinion. View "G.T. v. The Board of Education of the County of Kanawha" on Justia Law

In two separate class actions, Kenneth Hasson and Jordan Schnur alleged that FullStory, Inc. and Papa John’s International, Inc. unlawfully wiretapped their online communications using FullStory’s Session Replay Code. This code intercepts detailed user interactions on websites without user consent. Hasson, a Pennsylvania resident, claimed FullStory wiretapped him while he browsed Mattress Firm’s website. Schnur, also from Pennsylvania, alleged similar wiretapping by Papa John’s website.The United States District Court for the Western District of Pennsylvania dismissed both cases for lack of personal jurisdiction. In Hasson’s case, the court found that FullStory, a Delaware corporation with its principal place of business in Georgia, did not have sufficient contacts with Pennsylvania. The court denied Hasson’s request for jurisdictional discovery. In Schnur’s case, the court ruled that Papa John’s, also a Delaware corporation with its principal place of business in Georgia, did not expressly aim its conduct at Pennsylvania, despite operating numerous restaurants in the state.The United States Court of Appeals for the Third Circuit reviewed these dismissals. The court affirmed the dismissal in Schnur’s case, agreeing that Schnur failed to show that Papa John’s expressly aimed its conduct at Pennsylvania under the Calder “effects” test. The court noted that merely operating a website accessible in Pennsylvania does not establish personal jurisdiction.However, the court vacated the dismissal in Hasson’s case and remanded it for further consideration. The court held that the District Court should have also considered whether personal jurisdiction was proper under the traditional test as articulated in Ford Motor Co. v. Montana Eighth Judicial District Court. This test examines whether the defendant purposefully availed itself of the forum and whether the plaintiff’s claims arise out of or relate to the defendant’s contacts with the forum. The court instructed the District Court to reassess FullStory’s contacts with Pennsylvania under this framework. View "Hasson v. Fullstory Inc" on Justia Law

Brian Houston, representing a putative class, filed a lawsuit against Maricopa County and Sheriff Paul Penzone, alleging that the County's practice of posting arrestees' photographs and identifying information on its Mugshot Lookup website violated his substantive and procedural due process rights and his right to a speedy public trial. Houston's mugshot and personal details were posted online for three days following his arrest, even though he was never prosecuted. He claimed this caused him public humiliation, reputational harm, and emotional distress.The United States District Court for the District of Arizona dismissed Houston's claims. The court found that the Mugshot Lookup post was not a condition of pretrial detention and that Houston failed to show a cognizable liberty or property interest under state law for his procedural due process claim. The court also dismissed his Sixth Amendment claim, noting that Houston was not prosecuted and thus had no trial.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court's dismissal of Houston's substantive due process claim, holding that Houston sufficiently alleged that the Mugshot Lookup post caused him actionable harm and that the County's transparency justification did not rationally relate to the punitive nature of the post. The court affirmed the dismissal of Houston's procedural due process claim, as he did not demonstrate a protected liberty or property interest under state law. The court also affirmed the dismissal of his Sixth Amendment claim, as Houston was not prosecuted and thus had no right to a speedy trial.The Ninth Circuit concluded that Houston adequately pleaded a substantive due process claim but failed to state claims for procedural due process and Sixth Amendment violations. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "HOUSTON V. MARICOPA COUNTY" on Justia Law

In the wake of George Floyd's death in May 2020, Los Angeles experienced widespread protests. The plaintiffs, including Black Lives Matter Los Angeles and several individuals, filed a class action lawsuit against the City of Los Angeles and then-LAPD Chief Michel Moore. They alleged that the LAPD used excessive force, arrested protestors without probable cause, and restricted their First Amendment rights. The lawsuit sought to certify four classes: a Direct Force Class, an Arrest Class, an Infraction Class, and an Injunctive Relief Class.The United States District Court for the Central District of California certified all four classes. The court found that the plaintiffs had raised common questions about whether LAPD customs or policies caused their injuries. However, the district court did not rigorously analyze whether the damages classes satisfied the commonality requirement under Rule 23(a) or whether common questions predominated over individual ones under Rule 23(b)(3). The court also failed to address whether the Injunctive Relief Class met the commonality requirement under Rule 23(a).The United States Court of Appeals for the Ninth Circuit vacated the district court’s class certification order. The Ninth Circuit held that the district court did not rigorously analyze whether the plaintiffs produced sufficient evidence to meet the class certification requirements. Specifically, the district court did not adequately address the commonality and predominance requirements for the damages classes or identify common questions for the Injunctive Relief Class. The Ninth Circuit remanded the case with instructions for the district court to fully address Rule 23’s class certification requirements. View "BLACK LIVES MATTER LOS ANGELES V. CITY OF LOS ANGELES" on Justia Law

John Doe, a patient at Ridgeview Institute – Monroe, sued the facility's owners, operators, and CEO after a former employee, Rhonda Rithmire, disclosed patient information without authorization. Doe sought to represent a class of affected patients, alleging multiple claims including breach of contract and negligence. The trial court denied Doe's motion for class certification, finding that he failed to meet the commonality and typicality requirements under OCGA § 9-11-23 (a). Specifically, the court noted that Doe's disclosed information did not include diagnosis or treatment details, unlike other patients whose more sensitive information was revealed.Doe appealed to the Court of Appeals of Georgia, which reversed the trial court's decision. The appellate court found that Doe's claims and those of the putative class arose from the same events and were based on the same legal theories, thus satisfying the typicality requirement. One judge dissented, disagreeing with the majority's interpretation of the typicality and commonality requirements.The Supreme Court of Georgia reviewed the case to determine if the trial court abused its discretion in denying class certification. The Supreme Court concluded that the trial court acted within its discretion in finding a lack of typicality. The court noted that the differences in the type of information disclosed among class members could lead to different legal theories and defenses, making Doe's claims not typical of the class. As a result, the Supreme Court reversed the Court of Appeals' decision, upholding the trial court's denial of class certification. The court did not address the commonality issue, as the lack of typicality alone was sufficient to deny class certification. View "VEST MONROE, LLC v. DOE" on Justia Law

Pilar Domer placed an online order for a can of paint from Menards, selecting an in-store pickup option that incurred a $1.40 fee. Domer later filed a class action lawsuit against Menards, alleging that the company failed to disclose the pickup fee and used it to manipulate prices. Menards moved to compel arbitration based on an arbitration clause in their online terms of order. The district court granted Menards' motion, finding that Domer had agreed to the arbitration terms and that her claims fell within the scope of the arbitration agreement.The United States District Court for the Western District of Wisconsin ruled in favor of Menards, determining that the arbitration agreement was enforceable. The court found that Menards provided adequate notice of the terms and that Domer had unambiguously agreed to them by completing her purchase. The court also concluded that Domer’s claims were related to her purchase contract with Menards and thus fell within the scope of the arbitration agreement.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that Menards' website provided reasonably conspicuous notice of the terms, and Domer unambiguously manifested her assent by submitting her order. The court also found that Domer’s claims, which included violations of consumer protection laws and unjust enrichment, arose from or related to her purchase contract with Menards. Therefore, the claims were within the scope of the arbitration agreement. The Seventh Circuit concluded that the arbitration agreement was valid and enforceable, and Domer’s claims must be arbitrated. View "Domer v. Menard, Inc." on Justia Law