Justia Class Action Opinion Summaries
Articles Posted in Class Action
MELENDRES V. SKINNER
The case involves a class action lawsuit against the Maricopa County Sheriff’s Office (MCSO) for racially profiling Latino drivers and passengers under the guise of immigration enforcement. Plaintiffs sought declaratory and injunctive relief for violations of their Fourth and Fourteenth Amendment rights. The district court issued a permanent injunction in 2013, followed by a supplemental injunction appointing an independent monitor to oversee MCSO’s compliance. In 2016, a second supplemental injunction required MCSO to reform its internal misconduct investigation procedures. In 2022, a third supplemental injunction found the Sheriff in contempt for non-compliance and set forth curative measures, including creating a Constitutional Policing Authority (CPA) and assigning its duties to the Monitor.The United States District Court for the District of Arizona initially issued the permanent injunction and subsequent supplemental injunctions. The court found MCSO in contempt for failing to comply with the injunctions and ordered additional remedial measures. The district court relied on its inherent equitable powers rather than Federal Rule of Civil Procedure 53 in issuing these orders.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the district court’s amended third supplemental permanent injunction. It held that the district court acted within its inherent equitable powers in assigning the CPA’s duties to the Monitor. The court rejected the Sheriff’s contention that this assignment violated Article III of the Constitution and separation of powers principles. It also found that the First Order provided adequate judicial review of the Monitor’s actions and that the Third Order did not contravene Federal Rule of Civil Procedure 65’s specificity requirement. The Ninth Circuit concluded that the district court’s actions were appropriate and affirmed the Third Order. View "MELENDRES V. SKINNER" on Justia Law
JAMA V. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY
Plaintiffs, representing a class of drivers whose cars were totaled in accidents, alleged that their insurers, State Farm Mutual Automobile Insurance Company and State Farm Fire and Casualty Company, failed to pay the actual cash value of their vehicles. They contended that State Farm applied two unlawful discounts: a negotiation discount, which reduced the value based on typical buyer negotiations, and a condition discount, which adjusted for the car's condition compared to similar vehicles.The United States District Court for the Western District of Washington initially certified two classes: a negotiation class and a condition class. However, following the Ninth Circuit's decision in Lara v. First National Insurance Company of America, the district court decertified both classes and granted summary judgment in favor of State Farm, concluding that the plaintiffs failed to demonstrate injury.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court's decertification of the negotiation class, holding that plaintiffs could prove injury on a class-wide basis by adding back the unlawful negotiation adjustment to determine the value each class member should have received. However, the court affirmed the decertification of the condition class, as determining injury required an individualized comparison of the unlawful condition adjustment and a hypothetical lawful adjustment.The Ninth Circuit also vacated the district court's summary judgment against the named plaintiffs, remanding the case for the district court to reassess whether the plaintiffs provided sufficient evidence of injury. The court clarified that plaintiffs could rely on the Autosource reports, minus the unlawful adjustments, as relevant evidence of injury. The court rejected State Farm's argument that Article III standing was a barrier to the plaintiffs' suit, affirming that the plaintiffs' claim of receiving less than owed under their insurance policies constituted a concrete injury. View "JAMA V. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY" on Justia Law
Jackson-Mau v. Walgreen Co.
A consumer of a glucosamine-based dietary supplement filed a putative class action lawsuit against the supplement’s manufacturer and retailer under New York law. The plaintiff alleged that the supplement was mislabeled because it contained a different formulation of glucosamine than what was displayed on the front of the label and disclosed as the main ingredient on the side. Specifically, the plaintiff claimed that the product contained blended glucosamine rather than single-crystal glucosamine, which she believed to be more effective for alleviating joint pain.The United States District Court for the Eastern District of New York granted summary judgment for the defendants on federal preemption grounds. The court concluded that the plaintiff’s state law mislabeling claims were preempted by the Food, Drug, and Cosmetic Act (FDCA), which establishes national standards for the labeling of dietary supplements. The district court found that the FDCA’s comprehensive regulatory scheme and its broad preemption clauses foreclosed the plaintiff’s state law claims.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that the plaintiff’s state law mislabeling claims were expressly preempted by the FDCA. The court reasoned that the FDCA preempts any state law that imposes labeling requirements not identical to those set forth in the FDCA and its regulations. The court found that the product’s labeling complied with the FDCA’s requirements, as the dietary ingredient “glucosamine sulfate potassium chloride” was identified using methods endorsed by the FDA. Therefore, the plaintiff’s claims were preempted, and the judgment of the district court was affirmed. View "Jackson-Mau v. Walgreen Co." on Justia Law
In re Dell Technologies Inc.
The case involves a dispute over attorneys' fees following a $1 billion settlement in litigation challenging Dell Technologies' redemption of Class V stock. The plaintiff, Steamfitters Local 449 Pension Plan, alleged that Dell Technologies, controlled by Michael Dell and Silver Lake Group LLC, redeemed the Class V stock at an unfair price. The litigation was complex, involving extensive discovery and expert testimony, and was settled on the eve of trial.The Court of Chancery of the State of Delaware awarded 26.67% of the settlement, or $266.7 million, as attorneys' fees. Pentwater Capital Management LP and other class members objected, arguing that the fee was excessive and that a declining percentage method should be applied, similar to federal securities law cases. The Court of Chancery rejected this argument, holding that Delaware law, as established in Sugarland Industries, Inc. v. Thomas and Americas Mining Corp. v. Theriault, does not mandate a declining percentage approach. The court found that the $1 billion settlement was a significant achievement and that the fee award was justified based on the results achieved, the time and effort of counsel, and other relevant factors.The Supreme Court of the State of Delaware reviewed the case and affirmed the Court of Chancery's decision. The Supreme Court held that the Court of Chancery did not exceed its discretion in awarding 26.67% of the settlement as attorneys' fees. The court emphasized that the Sugarland factors, particularly the results achieved, are paramount in determining fee awards. The Supreme Court also noted that while a declining percentage approach is permissible, it is not mandatory, and the Court of Chancery adequately justified its decision not to apply it in this case. View "In re Dell Technologies Inc." on Justia Law
Zaragoza v. Union Pacific Railroad
Robert Anthony Zaragoza, a former brakeman and train conductor for Union Pacific Railroad Company, was terminated in 2015 after testing positive for cocaine but was later reinstated. In 2016, he failed a color vision test and subsequent retests, leading to his removal from service and denial of recertification as a conductor. Zaragoza contested these results, submitting medical reports attesting to his adequate color vision, but was not reinstated.Zaragoza argued that his claims were tolled from 2016 to 2020 due to his inclusion in a class action against Union Pacific, Harris v. Union Pacific Railroad Co. The district court for the Western District of Texas dismissed his claims as untimely, finding that the tolling ended with the class certification order in February 2019, and the statute of limitations expired before Zaragoza filed his EEOC charge in March 2020.The United States Court of Appeals for the Fifth Circuit reviewed the case and determined that Zaragoza was included in both the putative and certified class definitions in the Harris class action. The court held that the statute of limitations for Zaragoza's claims was tolled during the pendency of the Harris class action, from the time his claims accrued until the Eighth Circuit decertified the class in March 2020. Consequently, Zaragoza's claims were timely when he filed his EEOC charge.The Fifth Circuit reversed the district court's dismissal of Zaragoza's disability discrimination claims and remanded the case for further proceedings, declining to address Union Pacific's alternate grounds for summary judgment. View "Zaragoza v. Union Pacific Railroad" on Justia Law
M.H. v. Commissioner, Georgia Dept. of Community Health
The case involves a class action lawsuit brought by several minor children, through their legal guardians, against the Commissioner of the Georgia Department of Community Health. The plaintiffs challenged the Department's practices regarding the provision of skilled nursing services under the Medicaid Act. Specifically, they contested the Department's use of a scoresheet to determine the number of skilled nursing hours and the practice of reducing those hours as caregivers learn to perform skilled tasks.The United States District Court for the Northern District of Georgia granted summary judgment in favor of the plaintiffs. The court ruled that the Department's review process did not give appropriate weight to the recommendations of treating physicians and that the practice of reducing skilled nursing hours as caregivers learn skilled tasks violated the Medicaid Act. The district court issued permanent injunctions requiring the Department to approve the skilled nursing hours prescribed by the patients' treating physicians.The United States Court of Appeals for the Eleventh Circuit reviewed the case and reversed the district court's decision. The appellate court held that the Department's review process, which includes the use of a scoresheet to determine a presumptive range of skilled nursing hours, complies with the Medicaid Act. The court also found that the practice of reducing skilled nursing hours as caregivers learn skilled tasks is reasonable and does not violate the Act. The court vacated the permanent injunctions and remanded the case for further proceedings. The appellate court did not address the plaintiffs' challenge regarding the consideration of caregiver capacity, as the district court had ruled that issue moot. The appeal of the preliminary injunctions was deemed moot following the vacatur of the permanent injunctions. View "M.H. v. Commissioner, Georgia Dept. of Community Health" on Justia Law
COX V. COINMARKETCAP OPCO, LLC
Ryan Cox filed a class action lawsuit alleging that the defendants manipulated the price of a cryptocurrency called HEX by artificially lowering its ranking on CoinMarketCap.com. The defendants include two domestic companies, a foreign company, and three individual officers of the foreign company. Cox claimed that the manipulation caused HEX to trade at lower prices, benefiting the defendants financially.The United States District Court for the District of Arizona dismissed the case for lack of personal jurisdiction, concluding that Cox needed to show the defendants had sufficient contacts with Arizona before invoking the Commodity Exchange Act's nationwide service of process provision. The court found that none of the defendants had sufficient contacts with Arizona.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the Commodity Exchange Act authorizes nationwide service of process independent of its venue requirement. The court concluded that the district court had personal jurisdiction over the U.S. defendants, CoinMarketCap and Binance.US, because they had sufficient contacts with the United States. The court also found that Cox's claims against these defendants were colorable under the Commodity Exchange Act. Therefore, the court reversed the district court's dismissal of the claims against the U.S. defendants and remanded for further proceedings.However, the Ninth Circuit affirmed the district court's dismissal of the claims against the foreign defendants, Binance Capital and its officers, due to their lack of sufficient contacts with the United States. The court vacated the dismissal "with prejudice" and remanded with instructions to dismiss the complaint against the foreign defendants without prejudice. View "COX V. COINMARKETCAP OPCO, LLC" on Justia Law
Oyoma Asinor v. DC
The appellants in this case were arrested by the Metropolitan Police Department (MPD) during protests in August 2020. Upon arrest, their personal property, including cell phones, was seized. They were released without charges, but their property was not returned for months or even over a year, despite repeated requests. The appellants filed motions under D.C. Rule of Criminal Procedure 41(g) to recover their property, which led to the return of some items after significant delays. They then sued the District of Columbia in federal court, alleging violations of the Fourth and Fifth Amendments and common-law conversion, and sought damages and injunctive relief.The United States District Court for the District of Columbia dismissed the complaints. It held that the plaintiffs failed to state a Fourth Amendment claim because the initial seizure was reasonable and any challenge to continued retention was governed by the Fifth Amendment. The court also found that Rule 41(g) provided adequate process for the Fifth Amendment claim. Consequently, it declined to exercise supplemental jurisdiction over the conversion claim and denied class certification as moot.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Fourth Amendment requires that any continued retention of personal property seized incident to a lawful arrest must be reasonable. The court found that the prolonged retention of the appellants' property without a legitimate investigatory or protective purpose could constitute an unreasonable seizure under the Fourth Amendment. The court reversed the dismissal of the Fourth Amendment claims, vacated the dismissal of the D.C.-law claims and the denial of class certification, and remanded the case for further proceedings. View "Oyoma Asinor v. DC" on Justia Law
Taylor v. Tesla, Inc.
Four former Tesla employees, Sharonda Taylor, Shaka Green, Tatianna Smith, and Zenobia Milligan, requested personnel records from Tesla through their counsel, Bryan Schwarz Law (BSL), under the California Labor Code. These individuals are also part of a class action lawsuit, Vaughn v. Tesla, which alleges racial discrimination and harassment at Tesla's Fremont factory. During the Vaughn litigation, BSL sent Tesla privacy waivers and statutory personnel records requests on behalf of numerous employees, including the plaintiffs. Tesla did not respond to these requests, citing a stay in the Vaughn proceedings due to an appeal.The Superior Court of California, County of Alameda, denied Tesla's anti-SLAPP motion, which sought to strike the plaintiffs' PAGA complaint. The court found that Tesla failed to show that the plaintiffs' claims arose from protected petitioning activity under the anti-SLAPP statute. The court ruled that the plaintiffs were exercising their statutory rights to inspect and copy personnel records, independent of the Vaughn litigation.The California Court of Appeal, First Appellate District, Division Four, affirmed the lower court's decision. The appellate court held that Tesla's refusal to provide the requested personnel records did not constitute protected petitioning activity under the anti-SLAPP statute. The court distinguished this case from Crossroads Investors, L.P. v. Federal National Mortgage Assn., noting that the plaintiffs' claims did not involve any "written or oral statement or writing" by Tesla. The court also found that Tesla's conduct did not further any public issue or contribute to public debate, as required under the anti-SLAPP statute's catchall provision. Consequently, the appellate court affirmed the denial of Tesla's anti-SLAPP motion. View "Taylor v. Tesla, Inc." on Justia Law
MAX ROYAL LLC V. ATIEVA, INC.
Plaintiff-investors brought a securities fraud class action against Atieva, Inc., d/b/a Lucid Motors, and its CEO, Peter Rawlinson. They alleged that Rawlinson made misrepresentations about Lucid's production capabilities, which affected the stock price of Churchill Capital Corp. IV (CCIV), a special purpose acquisition company (SPAC) in which the plaintiffs were shareholders. These misrepresentations were made before Lucid was acquired by CCIV. Plaintiffs purchased CCIV stock based on these statements but did not own any Lucid stock, as Lucid was privately held at the time.The United States District Court for the Northern District of California initially held that the plaintiffs had statutory standing but dismissed the action for failure to allege a material misrepresentation. The court allowed plaintiffs to amend their complaint, but ultimately denied the amendments as futile and dismissed the case with prejudice, concluding that the plaintiffs had not plausibly alleged materiality.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s dismissal on an alternative ground. The Ninth Circuit held that the plaintiffs lacked standing under Section 10(b) of the Exchange Act, following the Birnbaum Rule, which limits standing to purchasers or sellers of the stock in question. The court agreed with the Second Circuit's precedent in Menora Mivtachim Ins. Ltd. v. Frutarom Indus. Ltd., holding that purchasers of a security of an acquiring company (CCIV) do not have standing to sue the target company (Lucid) for alleged misstatements made prior to the merger. Consequently, the Ninth Circuit affirmed the dismissal of the suit on the ground that the plaintiffs lacked standing. View "MAX ROYAL LLC V. ATIEVA, INC." on Justia Law