Justia Class Action Opinion Summaries

In this case, plaintiffs in a class action alleged that several corporations in the broiler chicken market violated antitrust laws by engaging in bid rigging and reducing the supply of broiler chickens. The plaintiffs claimed that these actions led to anomalous dips in sales, which they attributed to collusion on price and output. The class action was divided into two tracks: Track 1, which omitted bid-rigging allegations for faster discovery and trial, and Track 2, which included bid-rigging theories and state law claims by indirect purchasers.The United States District Court for the Northern District of Illinois allowed the class to place claims against Simmons Foods, Inc. and Simmons Prepared Foods, Inc. on Track 1. Simmons settled for $8 million, but several class members, including the Boston Market group, objected to the settlement. They argued that the settlement was inadequate and that they should not be included in the class because they had filed their own antitrust suits. However, they missed the deadline to opt out of the class, and the district court approved the settlement.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the settlement's release language was broad enough to cover bid-rigging claims and that the $8 million settlement was reasonable. The court noted that the Boston Market group did not provide evidence that the settlement amount was unreasonably low. Additionally, the court observed that the class had lost a related trial and that criminal antitrust prosecutions against some firms had ended in mistrials or acquittals, indicating uncertainty about the plaintiffs' prospects. The court affirmed the district court's approval of the settlement. View "Boston Market Corporation v Mountainaire Farms, Inc." on Justia Law

Paul Osheske, a Facebook user, purchased a movie ticket on Landmark Theatres' website. Landmark Theatres, operated by Silver Cinemas Acquisition Co., shared the name of the film, the location of the showing, and Osheske’s unique Facebook identification number with Facebook without his consent. Osheske filed a class action lawsuit against Landmark, alleging that this disclosure violated the Video Privacy Protection Act (VPPA).The United States District Court for the Central District of California dismissed Osheske’s complaint, concluding that Landmark Theatres did not qualify as a “video tape service provider” under the VPPA. The court reasoned that the activities of selling tickets and providing an in-theater movie experience did not fall under the VPPA’s definition of “rental, sale, or delivery of prerecorded video cassette tapes or similar audio visual materials.”The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s dismissal. The Ninth Circuit held that the VPPA does not apply to businesses providing a classic in-theater moviegoing experience. The court determined that the statutory text and historical context of the VPPA indicate that the Act was intended to cover the rental, sale, or delivery of video products, not the provision of shared access to film screenings in a theater. Consequently, Landmark Theatres' conduct did not make it a “video tape service provider” under the VPPA. The court also noted that the district court’s dismissal without leave to amend was proper, as the complaint could not be saved by any amendment. View "OSHESKE V. SILVER CINEMAS ACQUISITION COMPANY" on Justia Law

Plaintiffs, Glacier County taxpayers, alleged that the County and its Commissioners unlawfully made expenditures or disbursements of public funds or incurred obligations in excess of total appropriations, violating Montana law. The case originated from a 2015 lawsuit by Plaintiff Elaine Mitchell, who claimed the County and State failed to comply with the Single Audit Act and the Local Government Budget Act. An independent audit revealed deficit balances in many county funds, prompting the lawsuit. The plaintiffs sought various forms of relief, including declarations of non-compliance with accounting standards and laws ensuring government financial accountability.The Ninth Judicial District Court granted partial summary judgment to Plaintiffs on the issue of the County's improper liquidation of a tax protest fund. Plaintiffs then filed a motion to certify Count II as a class action, which the District Court granted, defining the class as property taxpayers of Glacier County who paid taxes from 2012 to 2020. The County appealed the class certification order and the denial of its motion to dismiss for lack of standing.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court's decisions. The Court held that Plaintiffs had standing, as they alleged concrete economic injuries from the County's actions, such as increased tax obligations and loss of county services. The Court also found that the class met the prerequisites for certification under M. R. Civ. P. 23(a), including numerosity, commonality, typicality, and adequate representation. The Court ruled that common questions of law and fact predominated over individual questions, making a class action the superior method for adjudicating the controversy. The class certification was affirmed, and the case was remanded for further proceedings. View "Gottlob v. DesRosier" on Justia Law

Francisco Rosario filed a class action lawsuit against Nationstar Mortgage, LLC (Mr. Cooper) and The Bank of New York Mellon (BNYM), alleging that they collected illegal and unlicensed third-party loan servicing fees on his mortgage. Rosario claimed that these fees were prohibited by the mortgage contract and Rhode Island law. He sought to represent all similarly situated individuals who were charged these fees.The Superior Court granted the defendants' motion to dismiss the complaint. The court found that Rosario's claims were based on a statute that did not provide a private right of action for borrowers to recoup fees collected by unlicensed loan servicers. Rosario appealed the decision, arguing that the defendants breached the mortgage contract by charging fees in violation of Rhode Island law and that the statute should be interpreted broadly to include loan servicing activities.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's decision. The court held that the statute in question, G.L. 1956 § 19-14.11-1, did not provide a private right of action for borrowers to recover fees collected by unlicensed loan servicers. The court also found that the statute's exception for unlicensed transactions involving lending or loan brokering did not apply to loan servicing activities. Therefore, the court concluded that Rosario's breach of contract claim could not be sustained based on the alleged statutory violations. The order of the Superior Court was affirmed. View "Rosario v. Nationstar Mortgage, LLC" on Justia Law

Three Coast Guard servicemembers, Eric Jackson, Alaric Stone, and Michael Marcenelle, objected to a COVID-19 vaccination mandate issued by the Coast Guard, which operates under the Department of Homeland Security. Their requests for religious accommodations were denied, and they faced reprimands for refusing the vaccination. They filed a class action lawsuit against the Secretaries of Homeland Security and Defense, the Commandant of the Coast Guard, and the Assistant Commandant for Human Resources, alleging violations of the Religious Freedom Restoration Act, the First Amendment, and the Administrative Procedure Act. They sought declaratory and injunctive relief.The United States District Court for the Northern District of Texas dismissed the case as moot after the Department of Defense rescinded its vaccination mandate, and the Coast Guard followed suit. The Plaintiffs' motion for relief from final judgment was also denied, leading to their appeal.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s Rule 12(b)(1) dismissal de novo. The appellate court found that the case was not moot because the Coast Guard had not issued policies protecting unvaccinated servicemembers from discrimination, unlike the Navy, which had implemented such protections. The court noted that the Plaintiffs could still face adverse actions based on their vaccination status and that a court order could provide effective relief. Consequently, the Fifth Circuit reversed the district court’s decision and remanded the case for further proceedings. View "Jackson v. Noem" on Justia Law

Tracy Hall filed a class action lawsuit against Walgreens Boots Alliance, Inc. and Walgreen Co., alleging that the company deceptively marketed a cough medicine containing dextromethorphan hydrobromide as "nondrowsy," despite drowsiness being a known side effect. The FDA regulates over-the-counter medicines, including antitussives, but does not require a drowsiness warning for the specific drug in question. Hall claimed that the labeling violated Washington's Consumer Protection Act (CPA).The United States District Court for the Northern District of Illinois reviewed the case and denied Walgreens' motion to dismiss. Walgreens argued that the labeling fell within the CPA's statutory safe harbor, which exempts actions permitted by regulatory bodies. The federal court then certified the question to the Supreme Court of the State of Washington, asking whether the labeling decision fell within the statutory safe harbor under RCW 19.86.170.The Supreme Court of the State of Washington concluded that the statutory safe harbor applies only to actions expressly permitted by a regulatory body. Since the FDA had not specifically permitted labeling the cough medicine as "nondrowsy," the court held that the activity did not fall within the statutory safe harbor. The court answered the certified question in the negative, indicating that the labeling did not qualify for the exemption under the CPA. View "Hall v. Walgreens Boots Alliance, Inc." on Justia Law

In 1990, a group of California state prisoners filed a lawsuit alleging that the State of California violated the Eighth Amendment by failing to provide adequate mental health care in its prisons. The plaintiffs, who later achieved class certification, prevailed in a 1995 bench trial, and the State was found to be in violation of its Eighth Amendment obligations. Despite efforts to develop and implement remedial plans, the State remained noncompliant with court orders to reduce mental health care provider staffing vacancies to fixed levels.The United States District Court for the Eastern District of California issued several orders over the years to address the staffing issues, including a 2017 order requiring the State to achieve a maximum ten percent vacancy rate for mental health care providers. By 2023, the State had not complied, leading the district court to establish a schedule of prospective fines for continued noncompliance. After finding persistent noncompliance, the district court issued final contempt findings in 2024, resulting in over $110 million in fines.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's decision to hold the State in civil contempt. The Ninth Circuit agreed that the State failed to establish a substantial compliance defense or an impossibility defense. The court also held that the contempt fines were civil in nature and did not require criminal due process protections. However, the Ninth Circuit vacated the fines to the extent they exceeded the State’s monthly salary savings and remanded the case for additional findings and analysis regarding the exact amount of fines to be imposed. View "Coleman v. Newsom" on Justia Law

Connie Lange purchased a fifth-wheel camping trailer from GMT Auto Sales in August 2020, which included a $199 administrative fee. Lange later filed a class action petition alleging that GMT violated the Missouri Merchandising Practices Act by charging this fee, arguing that fifth-wheel camping trailers do not qualify as "motor vehicles," "vessels," or "vessel trailers" under the relevant statute. GMT initially moved to dismiss the case but later moved to compel arbitration based on an arbitration clause in the retail installment contract.The Circuit Court of St. Louis County overruled GMT's motion to dismiss and later granted GMT's motion to compel arbitration. The arbitrator awarded Lange $199 and $5,000 in attorney fees. Lange then filed a motion to vacate the arbitration award and reconsider the order compelling arbitration, which the circuit court denied. Lange appealed, arguing that GMT waived its right to arbitration by filing the motion to dismiss and that the arbitration provision was unenforceable.The Missouri Court of Appeals reversed the circuit court's judgment, agreeing with Lange that GMT waived its right to arbitration. The Supreme Court of Missouri granted transfer and reviewed the case de novo. The court found that GMT did not waive its right to arbitration by filing the motion to dismiss, as it timely moved to compel arbitration and raised it as an affirmative defense in its responsive pleading. The court also found that the arbitration provision remained enforceable despite the assignment of the retail installment contract to a bank. Lange's argument regarding the unconscionability of the arbitration provision was deemed unpreserved for review.The Supreme Court of Missouri affirmed the circuit court's judgment confirming the arbitration award. View "Lange v. GMT Auto Sales, Inc." on Justia Law

Plaintiffs MSP Recovery Claims, Series LLC; MSPA Claims 1, LLC; and Series PMPI filed a lawsuit in September 2018 against Fresenius Medical Care Holdings and related entities, alleging negligence, product liability, and design defect claims related to the GranuFlo product used in hemodialysis treatments. The claims arose from a 2012 public memorandum by Fresenius that GranuFlo could lead to cardiopulmonary arrest. The plaintiffs argued that the statute of limitations was tolled by a putative class action filed in 2013 (the Berzas action) in the Eastern District of Louisiana, which was later transferred to the District of Massachusetts as part of multidistrict litigation (MDL).The District Court for the District of Massachusetts dismissed the plaintiffs' claims as time-barred, concluding that the Berzas action ceased to be a class action by June 2014 when the named plaintiffs filed Short Form Complaints or stipulations of dismissal, which did not include class allegations. The court also noted that the Berzas plaintiffs did not pursue class certification actively, and the case was administratively closed in April 2019.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The First Circuit held that the Berzas action lost its class action status by June 2014, and any tolling under American Pipe & Construction Co. v. Utah ended at that time. The court reasoned that allowing indefinite tolling based on an inactive class certification request would contravene the principles of efficiency and economy in litigation. Therefore, the plaintiffs' 2018 complaint was untimely, and the district court's dismissal was upheld. View "MSP Recovery Claims, Series LLC v. Fresenius Medical Care Holdings, Inc." on Justia Law

James Hulce, on behalf of himself and others similarly situated, filed a putative class action suit against Zipongo Inc., doing business as Foodsmart. Hulce alleged that Foodsmart violated the Telephone Consumer Protection Act (TCPA) by making unsolicited calls and sending text messages to him, despite his number being on the national do-not-call registry. Foodsmart's communications were about free nutritional services offered through Hulce's state and Medicaid-funded healthcare plan, Chorus Community Healthcare Plans (CCHP).The United States District Court for the Eastern District of Wisconsin granted Foodsmart's motion for summary judgment. The court found that the calls and messages did not constitute "telephone solicitations" under the TCPA because they were not made for the purpose of encouraging the purchase of services. Instead, the communications were about services that were free to Hulce, with Foodsmart billing CCHP directly.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that the calls and messages did not fall within the definition of "telephone solicitation" under the TCPA. The court concluded that "telephone solicitation" requires the initiation of a call or message with the purpose of persuading or urging someone to pay for a service. Since Foodsmart's communications were about free services and did not encourage Hulce to make a purchase, they did not meet this definition. The court emphasized that the purpose of the call must be to persuade someone who makes the purchasing decision to buy the services, which was not the case here. View "Hulce v Zipongo Inc." on Justia Law