Justia Class Action Opinion Summaries

Three Venezuelan nationals, alleged by the government to be members of the Tren de Aragua gang, were detained in Texas following a presidential proclamation under the Alien Enemies Act (AEA). This proclamation, issued in March 2025, authorized immediate removal of Venezuelan citizens aged fourteen or older, residing in the United States, who were not naturalized or lawful permanent residents and were identified as members of the gang. The petitioners challenged the proclamation, arguing that it exceeded the President’s authority under the AEA and violated due process rights. They sought class certification and injunctive relief to prevent removal under the AEA.The United States District Court for the Northern District of Texas denied temporary restraining orders and class certification. On appeal, the Fifth Circuit initially dismissed the case for lack of jurisdiction. The Supreme Court, in A.A.R.P. v. Trump, vacated that dismissal and remanded, instructing the Fifth Circuit to address two issues: whether the petitioners were entitled to a preliminary injunction against removal under the AEA, and whether the notice provided for due process claims was sufficient for the putative class. The Supreme Court also allowed the government to remove the petitioners under other lawful authorities.After remand, the three named petitioners were removed from the United States under the Immigration and Nationality Act (INA), not the AEA. The United States Court of Appeals for the Fifth Circuit concluded that, because the petitioners were no longer in the country and no class had been certified, it was impossible to grant any effectual relief. The Fifth Circuit dismissed the appeal as moot for lack of jurisdiction, declining to substitute new class representatives on appeal but leaving open the possibility for future proceedings in the district court. View "W.M.M. v. Trump" on Justia Law

A group of former students who attended ITT Technical Institute, a for-profit college, brought suit against companies and individuals involved in servicing and collecting on certain private student loans known as the PEAKS loans. After the 2008 financial crisis, ITT, needing to comply with federal regulations limiting reliance on federal funds, established the PEAKS loan program with the backing of Deutsche Bank to generate non-federal revenue. The loans were internally backed by guarantees from ITT, and as default rates rose, ITT concealed the program’s financial troubles from investors and regulators. The PEAKS loans continued to be serviced by Vervent, Inc. and its affiliates, even after ITT’s collapse and bankruptcy in 2016. Students alleged that they were not aware that their loan payments were induced by fraud until after ITT’s public downfall.In the United States District Court for the Southern District of California, the plaintiffs, as a putative class, alleged violations of the Racketeer Influenced and Corrupt Organizations Act (RICO) and various state-law claims. The defendants argued that the RICO claims were untimely, asserting that the statute of limitations began when the students received or began paying the loans, and also challenged proximate causation. The district court denied summary judgment on both grounds, finding fact issues precluded judgment as a matter of law. A jury found in favor of the plaintiffs, awarding damages that were trebled under RICO. The district court denied defendants’ post-trial motion for judgment as a matter of law.The United States Court of Appeals for the Ninth Circuit affirmed. It held there was sufficient evidence for the jury to find that the students neither knew nor reasonably should have known of their fraud-based injuries more than four years before suit was filed, so the claims were timely under RICO’s four-year statute of limitations. The court also concluded that defendants did not preserve their proximate cause argument for appeal because they did not properly raise it after trial. The judgment was affirmed. View "TURREY V. VERVENT, INC." on Justia Law

A software company operated an online payment portal used by residents, including the plaintiff, to pay rent for Maryland apartments. Each time the plaintiff paid rent through the portal, she was charged a convenience fee. To complete a transaction, users were required to check a box agreeing to the portal’s hyperlinked terms and conditions, which included an arbitration provision, a clause allowing unilateral changes to the agreement, and a notice provision stating that notices would be posted on the portal. The plaintiff, on behalf of herself and similarly situated individuals, filed a class action, alleging that the company unlawfully acted as an unlicensed collection agency by collecting these fees.After the action was removed to the U.S. District Court for the District of Maryland, the company moved to compel arbitration based on the terms and conditions. The plaintiff opposed, arguing that the arbitration agreement was unenforceable under Maryland law because the company’s ability to unilaterally change the terms without advance notice rendered its promise to arbitrate illusory. The district court agreed, finding that the contract was a browsewrap agreement and that the modification and notice clauses allowed the company to change terms at will without meaningful notice or an opportunity for users to opt out before changes became binding.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s denial of the motion to compel arbitration de novo. The Fourth Circuit held that, under Maryland law, the arbitration agreement was unenforceable for lack of consideration because the company’s promise to arbitrate was illusory. The court reasoned that the change-in-terms clause gave the company unfettered discretion to modify the agreement at any time, without advance notice, thus failing to bind the company meaningfully. The court affirmed the district court’s judgment. View "Trimble v. Entrata, Inc." on Justia Law

A group of life insurance policyholders sued Connecticut General Life Insurance Company and The Lincoln National Life Insurance Company, claiming that the companies wrongfully deducted inflated “cost of insurance” charges from the value of their life insurance policies. The lead plaintiff purchased her policy from Connecticut General, which was later administered by Lincoln following a business acquisition. The litigation in Connecticut overlapped with three similar class actions brought in Pennsylvania and New York against Lincoln and related companies, all alleging similar overcharging schemes.After years of litigation, the plaintiffs in the Connecticut case reached a settlement agreement with the defendants. This settlement aimed to resolve not only the Connecticut action but also the related actions in Pennsylvania and New York. Some class members from the related actions objected, arguing that the proposed settlement class failed to meet the requirements of Federal Rule of Civil Procedure 23, specifically the requirement that the claims of the class representatives be “typical” of those of the class. They pointed out that the named plaintiffs had policies directly issued by Connecticut General or Lincoln and could easily establish privity of contract, while many class members had policies issued by other Lincoln affiliates and would struggle to prove such privity.The United States District Court for the District of Connecticut rejected these objections, certified the settlement class, approved the settlement, and entered judgment for the plaintiffs. The objectors appealed.The United States Court of Appeals for the Second Circuit held that the typicality requirement of Rule 23(a)(3) was not met, relying on its prior decision in Mazzei v. Money Store, 829 F.3d 260 (2d Cir. 2016). The court found that the named plaintiffs’ claims were not typical because their ability to prove privity of contract was not shared by a substantial portion of the class. The Second Circuit reversed the class certification, vacated the judgment, and remanded for further proceedings. View "Glover v. Connecticut General Life Insurance Company" on Justia Law

Several individuals who purchased and used Samsung smartphones and tablets alleged that the preinstalled Samsung Gallery app created and stored face templates by scanning photographs for facial geometry, thereby capturing biometric data. They claimed that Samsung’s proprietary algorithm measured unique facial features, and the resulting face templates were stored locally on their devices. Plaintiffs argued that Samsung controlled the biometric data, since users had no way to disable the facial recognition features, and Samsung’s privacy policy indicated it “may collect” such information. They further contended that Samsung lacked a written policy for retention and destruction of biometric data and failed to provide required disclosures or obtain releases, in violation of the Illinois Biometric Privacy Information Act (“BIPA”).The plaintiffs initially filed their suit in Illinois state court, seeking class certification for all Illinois residents whose biometric data was collected or stored by Samsung. Samsung removed the case to the United States District Court for the Northern District of Illinois under the Class Action Fairness Act. After several amended complaints and motions to dismiss, the district court ultimately granted Samsung’s third motion to dismiss with prejudice, finding that the plaintiffs failed to plausibly allege that Samsung possessed or exerted control over the biometric data stored on users’ devices.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s dismissal de novo. The court held that under both Illinois law and BIPA, “possession,” “collection,” and “capture” require a degree of control by the company over the biometric data. Because the plaintiffs’ allegations did not plausibly show that Samsung itself controlled the facial geometry data generated by the app, the Court affirmed the district court’s judgment dismissing the complaint. View "G.T. v Samsung Electronics America, Inc." on Justia Law

The plaintiff purchased a portable speaker from a Wisconsin-based retailer, believing she was receiving a $30 discount off a regular price of $129.99. However, she later discovered that the retailer almost always sold the speaker at the “sale” price of $99.99 and rarely at the higher “regular” price. She claimed she would not have bought the speaker if she had known this, and brought suit on behalf of a proposed nationwide class, alleging the retailer had violated Wisconsin’s Unfair Trade Practices Act by using misleading price comparison advertising. The suit was filed in federal court, invoking the Class Action Fairness Act as the basis for subject matter jurisdiction.The United States District Court for the Western District of Wisconsin dismissed the complaint for lack of subject matter jurisdiction, finding that the plaintiff had not adequately alleged pecuniary loss under Wisconsin law. The court reasoned that, for damages under Wisconsin’s Unfair Trade Practices Act, the plaintiff must plead that the product was defective or worth less than the price paid, or otherwise did not receive the benefit of the bargain. Because the plaintiff did not make such allegations, the court concluded it was legally impossible for her to meet the required amount-in-controversy for class action jurisdiction.The United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. It found Wisconsin law unclear on whether a consumer who was misled by false price comparison advertising, but received a product worth the purchase price, suffers a pecuniary loss. Noting a split in authority and uncertainty in Wisconsin precedent, the appellate court certified this question to the Wisconsin Supreme Court and stayed further proceedings pending an answer. View "Cortez Gomez v Kohl's Corporation" on Justia Law

Several individuals arrested in Lancaster County, Pennsylvania, were detained pending trial after cash bail was set at their preliminary arraignments. At these arraignments, which were conducted via video without counsel present, the Magisterial District Judges allegedly imposed bail without considering the defendants’ ability to pay or other required factors under state law. Because they could not afford bail, the plaintiffs remained incarcerated. They brought a class action against four Magisterial District Judges (in their official capacities), Lancaster County, and the Warden of the county prison, alleging violations of their rights to equal protection, due process, and counsel.The United States District Court for the Eastern District of Pennsylvania first dismissed the plaintiffs’ Sixth Amendment claim, holding that the right to counsel attaches at the preliminary arraignment but does not require counsel’s presence at that proceeding, relying on Supreme Court precedent. The District Court later abstained from hearing the equal protection and due process claims under the doctrine established in Younger v. Harris, reasoning that federal intervention would improperly intrude upon ongoing state criminal proceedings and that state courts could address the plaintiffs’ bail-related claims.On appeal, the United States Court of Appeals for the Third Circuit reviewed both rulings. The Third Circuit held that Younger abstention was inappropriate because the plaintiffs did not seek to enjoin ongoing state criminal prosecutions but rather challenged procedures ancillary to those prosecutions—specifically, the process by which bail was set. Therefore, the District Court’s abstention was vacated and the matter remanded for further proceedings on the equal protection and due process claims. However, the Third Circuit affirmed the dismissal of the Sixth Amendment claim, holding that the preliminary arraignment under Pennsylvania law is not a “critical stage” requiring the presence of counsel, even though the right to counsel attaches at that point. View "Hartmann v. Chudzik" on Justia Law

Buyers of over-the-counter nasal decongestants containing oral phenylephrine brought numerous class actions against drug manufacturers and retailers, alleging that for years these companies sold and advertised decongestant products they knew to be ineffective. The plaintiffs claimed that scientific studies, particularly since 2016, had shown oral phenylephrine to be no better than a placebo at relieving congestion, yet the companies continued to market their products as effective decongestants and complied with Food and Drug Administration (FDA) labeling requirements. The FDA, despite mounting evidence, did not remove oral phenylephrine’s designation as an effective decongestant under its regulations.The Judicial Panel on Multidistrict Litigation consolidated nearly one hundred class actions and transferred them to the United States District Court for the Eastern District of New York. Plaintiffs filed a complaint asserting New York statutory and common-law claims as well as a federal RICO claim. The district court granted the defendants’ motion to dismiss, holding that the Federal Food, Drug, and Cosmetic Act (FDCA) expressly preempted the state law claims because the drugs’ labels complied with FDA requirements, and that the plaintiffs lacked standing to bring the RICO claim. The court also dismissed a Lanham Act claim brought by one pharmacy plaintiff.On appeal, the United States Court of Appeals for the Second Circuit held that the FDCA expressly preempts most of the state law claims because the federal regime requires manufacturers to follow the FDA-approved labeling, but it vacated the dismissal for claims regarding “Maximum Strength” labeling and brand-name drugs approved via the New Drug Application process, remanding those for further proceedings. The court affirmed dismissal of the RICO claim, adopting the indirect purchaser rule, and upheld denial of the pharmacy’s motion for reconsideration regarding its Lanham Act claim. View "Yousefzadeh v. Johnson & Johnson Consumer Inc." on Justia Law

A group of consumers who purchased products from a coffee company’s website filed a class action lawsuit, claiming that the website’s terms and conditions improperly restricted their right to post negative reviews about the company or its products. The website included clauses stating that users could not submit content intended to cause commercial harm or use the company’s trademarks in a way that would disparage the brand. The plaintiffs did not allege that the company ever threatened to enforce these provisions against them or that they experienced any economic harm as a result.In the Superior Court of Los Angeles County, the company responded with a demurrer, arguing that the plaintiffs failed to state a claim because merely including such provisions in the terms and conditions does not violate California Civil Code section 1670.8 unless there is an attempt to enforce or threaten enforcement of the provision. The court agreed, finding that section 1670.8 only permits a consumer to seek civil penalties when a business attempts to enforce or otherwise penalizes a consumer under such a clause, not merely for including the clause in a contract. The court also dismissed the plaintiffs’ related claim under the Unfair Competition Law, as no economic harm was alleged. The court denied leave to amend the Civil Code section 1670.8 claim and entered judgment in favor of the company.On appeal, the California Court of Appeal, Second Appellate District, Division One, reviewed the interpretation of section 1670.8. The appellate court held that while non-disparagement clauses in consumer contracts are void and unenforceable, a business can only be held liable for civil penalties if it threatens to enforce or seeks to enforce such a provision or penalizes a consumer for protected speech. The judgment of the trial court was affirmed. View "Arterberry v. Peet's Coffee" on Justia Law

A noncitizen from the Democratic Republic of the Congo was detained in New York pending removal proceedings and was ordered released on bond, which he could not pay. He then brought a class action and habeas petition on behalf of similarly situated noncitizens, challenging government bond-hearing procedures as violating due process. Specifically, he argued that the procedures wrongly placed the burden of proof on detainees, failed to consider ability to pay, and did not require consideration of alternatives to detention.The United States District Court for the Western District of New York initially certified the class and issued a preliminary injunction requiring changes to bond-hearing procedures, with the government complying for nearly two years. After the Supreme Court decided Garland v. Aleman Gonzalez, which held that lower courts lack jurisdiction to issue class-wide injunctive relief under certain immigration statutes, the district court vacated the injunction. It then decertified the class entirely, concluding that neither class-wide injunctive nor declaratory relief was appropriate, and dismissed the case.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the district court did not abuse its discretion in decertifying the class for injunctive relief, as lower courts lack authority for such relief post-Aleman Gonzalez. However, it found that the district court erred by decertifying the class for declaratory relief based on factors irrelevant to the Rule 23(b)(2) class-certification analysis. The Second Circuit clarified that while injunctive relief is unavailable, district courts retain authority to grant class-wide declaratory relief in these cases. Accordingly, the Second Circuit vacated the district court’s judgment and remanded for further proceedings. View "Onosamba-Ohindo v. Ball" on Justia Law