Justia Class Action Opinion Summaries

In late 2019, a hospital sent letters to over a thousand patients, including Linda Gierek, informing them of potential exposure to infectious diseases due to a technician's failure to fully sterilize surgical instruments. Gierek filed a class-action complaint against the hospital, asserting claims of negligent infliction of emotional distress, negligence, and medical malpractice. She sought class certification for similarly situated patients and their spouses. The trial court consolidated Gierek’s action with a similar class-action claim filed by Cheyanne Bennett.The Indiana Patient’s Compensation Fund intervened, arguing that the claims sounded in ordinary negligence and thus the Medical Malpractice Act (MMA) did not apply. The hospital argued the opposite. The trial court ruled in favor of the hospital, stating the MMA applied, and denied the motion for class certification, citing lack of subject-matter jurisdiction while a proposed complaint was pending before a medical-review panel. On appeal, the Court of Appeals affirmed the MMA’s applicability but reversed the trial court’s decision on class certification jurisdiction.The Indiana Supreme Court reviewed the case and held that the MMA covers all claims for medical malpractice, not limited to bodily injury or death. The court also held that class certification is a proper preliminary determination under the MMA. The court affirmed in part, reversed in part, and remanded the case for the trial court to consider the plaintiffs’ motion for class certification. View "Gierek v. Anonymous 1" on Justia Law

Linda Thompson filed a putative class action against the Army and Air Force Exchange Service (the "Exchange") in Illinois state court, alleging that the Exchange printed her credit card’s expiration date on purchase receipts, violating the Fair and Accurate Credit Transactions Act (FACTA). The Exchange removed the case to federal court under 28 U.S.C. § 1442(a)(1), which allows federal agencies to remove cases to federal court. Thompson moved to remand the case to state court, arguing lack of Article III standing, while the Exchange moved to dismiss under Federal Rule of Civil Procedure 12(b)(1).The United States District Court for the Southern District of Illinois denied Thompson’s motion to remand and granted the Exchange’s motion to dismiss for lack of subject matter jurisdiction. The court held that the Exchange, as a federal entity, could remove the case without asserting a colorable federal defense and had an absolute right to litigate in federal court.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court agreed that the Exchange did not need to present a federal defense to remove the case. However, it found that the district court erred in dismissing the suit. The Seventh Circuit held that under 28 U.S.C. § 1447(c), when a federal court lacks subject matter jurisdiction over a removed case, it must remand the case to state court. The court noted that Thompson’s lack of Article III standing did not preclude state court jurisdiction, as state courts are not bound by Article III constraints. Consequently, the Seventh Circuit vacated the district court’s judgment and remanded the case with instructions to remand it to state court. View "Thompson v Army and Air Force Exchange Service" on Justia Law

Plaintiffs filed two class action complaints against Experian Information Solutions, Inc. in Orange County Superior Court, alleging violations of the Fair Credit Reporting Act (FCRA). They claimed that Experian failed to include a required statement in the "Summary of Rights" portion of their consumer reports, which informs consumers of additional rights under state law. Plaintiffs sought actual, statutory, and punitive damages. Experian removed the cases to federal court, where Plaintiffs argued they lacked standing under Article III of the U.S. Constitution because they did not suffer concrete harm. The federal court agreed and remanded the cases back to state court.In state court, Experian moved for judgment on the pleadings, arguing that Plaintiffs lacked standing under Wisconsin law and that their FCRA claim did not fall within the "zone of interests" the FCRA is designed to protect. Plaintiffs contended that California law should apply and that they had standing under California law. The trial court granted Experian's motion, relying on the precedent set by Limon v. Circle K Stores Inc., which held that a plaintiff must allege a concrete injury to have standing in California state courts. Plaintiffs appealed the decision.The California Court of Appeal, Fourth Appellate District, reviewed the case and affirmed the trial court's judgment. The court found Limon persuasive and concluded that Plaintiffs lacked standing because they did not allege a concrete or particularized injury. The court held that an informational injury without adverse effects is insufficient to confer standing under California law. Therefore, the judgment in favor of Experian was affirmed. View "Muha v. Experian Information Solutions" on Justia Law

Julian Rodriguez, an hourly machine operator for Lawrence Equipment, Inc., filed a class action lawsuit in December 2015 alleging various wage-and-hour violations under the California Labor Code. Rodriguez claimed that Lawrence failed to pay for all hours worked, provide adequate meal and rest breaks, issue accurate wage statements, and pay final wages timely. In July 2014, Rodriguez had signed an arbitration agreement with Lawrence, which led to the arbitration of his non-PAGA claims. The arbitrator ruled in favor of Lawrence, finding that Rodriguez failed to prove any of the alleged Labor Code violations.The Superior Court of Los Angeles County confirmed the arbitration award and entered judgment in favor of Lawrence. Rodriguez appealed the judgment, but it was affirmed by the Court of Appeal. Subsequently, Lawrence moved for judgment on the pleadings, arguing that Rodriguez's remaining PAGA claim was barred by issue preclusion because the arbitrator had already determined that no Labor Code violations occurred. The trial court initially denied the motion but later granted it after the U.S. Supreme Court's decision in Viking River Cruises, Inc. v. Moriana, which influenced the court's interpretation of PAGA standing.The Court of Appeal of the State of California, Second Appellate District, Division Three, reviewed the case and affirmed the trial court's judgment. The appellate court held that the arbitrator's findings precluded Rodriguez from establishing standing as an aggrieved employee under PAGA. The court concluded that issue preclusion applied because the arbitrator's decision was final, the issues were identical, actually litigated, and necessarily decided, and the parties were the same. Consequently, Rodriguez lacked standing to pursue the PAGA claim, and the judgment of dismissal was affirmed. View "Rodriguez v. Lawrence Equipment, Inc." on Justia Law

In April 2013, Michael Riste applied for a bail bond for his son, Michael Peterson, and signed an Indemnity Agreement and a Premium Agreement with Bad Boys Bail Bonds (Bail Agent). The agreements required Riste to pay a $10,000 premium in installments. Peterson signed identical documents after his release. The Bail Agent executed a $100,000 bail bond on behalf of The North River Insurance Company (Surety), ensuring Peterson's appearance at future court proceedings. Peterson failed to appear, leading to the forfeiture of the bail bond and a summary judgment against the Surety in October 2015.The Superior Court of Los Angeles County denied appellants' previous motions to set aside the summary judgment, vacate the forfeiture, and exonerate the bond. Two different panels of the Court of Appeal affirmed these denials. In October 2020, a class action cross-claim was filed against BBBB Bonding Corporation (doing business as the Bail Agent), arguing that their bail bond premium financing agreements were subject to Civil Code section 1799.91 and thus unenforceable. The trial court agreed, and the Court of Appeal upheld this finding, affirming a preliminary injunction against BBBB.In September 2022, appellants filed a third motion to set aside the summary judgment, citing the Caldwell decision. They argued that the premium was part of the consideration for the bail bond, making the bond void and the summary judgment invalid. The trial court denied the motion.The California Court of Appeal, Second Appellate District, Division Three, affirmed the trial court's order. The court held that the bail bond was not void because the consideration for the bail bond was Peterson's release from custody, not the premium financing agreement. Therefore, the trial court had jurisdiction, and the summary judgment was valid. View "P. v. North River Ins. Co." on Justia Law

Phelps Oil and Gas, LLC, leased land to Noble Energy, Inc., which produces natural gas and pays royalties to Phelps. Phelps filed a class action lawsuit against Noble, alleging underpayment of royalties. The dispute centers on the interpretation of a prior settlement agreement, the Holman Settlement, which outlines the royalty calculation method. Phelps claims Noble failed to pay royalties on $34 million from a DCP Midstream, LP audit and $17.5 million that DCP promised to invest in infrastructure.The United States District Court for the District of Colorado granted summary judgment in favor of Noble. The court found that Noble was not obligated to pay royalties on the $34 million because DCP never returned those proceeds to Noble. Regarding the $17.5 million, the court held that Phelps failed to show that the promise had value to Noble beyond increased production and resulting revenues.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's decision, agreeing that Phelps did not present evidence that DCP returned any proceeds to Noble related to the $34 million. The court also upheld the summary judgment on the $17.5 million claim, finding that Phelps could not demonstrate that the promise provided any additional benefit to Noble aside from increased production and revenues, which Noble had already accounted for in its royalty payments.The Tenth Circuit concluded that Phelps failed to create a genuine issue of material fact regarding Noble's obligation to pay additional royalties under the Holman Settlement. The court affirmed the district court's judgment in favor of Noble Energy, Inc. View "Phelps Oil and Gas v. Noble Energy" on Justia Law

Residents of Humboldt County filed a putative class action under 42 U.S.C. § 1983, alleging that the County’s system of administrative penalties and fees for cannabis abatement violates the Eighth Amendment’s Excessive Fines Clause. The County Code imposes daily fines of $6,000 to $10,000 for illegal cannabis cultivation. Plaintiffs claimed that the County charges landowners based on imprecise data or previous owners' conduct, causing emotional distress and financial burdens due to ongoing penalties and abatement costs.The United States District Court for the Northern District of California dismissed the case, concluding that plaintiffs lacked standing as they had not paid any fines, rendering the Eighth Amendment claim unripe. The court also found both facial and as-applied challenges untimely, reasoning that the statute of limitations began when the ordinance was enacted.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that plaintiffs’ claim under the Excessive Fines Clause was constitutionally ripe and that they had standing due to the imposition of penalties causing concrete injuries, including emotional distress and financial expenses. The court also found that prudential ripeness considerations supported allowing the litigation to proceed. The court determined that the statute of limitations for facial challenges begins when plaintiffs know of the actual injury, not when the ordinance is enacted. Thus, some plaintiffs’ facial challenges were timely. The court also found that several plaintiffs had timely as-applied challenges, except for Cyro Glad, whose claim was untimely.On the merits, the Ninth Circuit held that plaintiffs plausibly alleged a violation of the Excessive Fines Clause, as the penalties and demolition orders were punitive and potentially excessive. The court reversed the district court’s dismissal of the Eighth Amendment claim and remanded for further proceedings, affirming the dismissal only for Cyro Glad’s as-applied claim. View "THOMAS V. COUNTY OF HUMBOLDT" on Justia Law

Pauline Mary Huff filed a class action and a Private Attorneys General Act (PAGA) action against her former employer, Interior Specialists, Inc., alleging various wage-and-hour violations. Huff opposed the motion to compel arbitration, arguing that the arbitration agreement was invalid because it was signed by someone else named "William" in DocuSign. The trial court found sufficient evidence that Huff consented to the agreement and granted the motion to compel arbitration.The trial court consolidated the class and PAGA actions. Interior Specialists then moved to compel Huff’s PAGA claims to arbitration. The trial court reiterated its earlier finding that Huff validly signed the agreement and, relying on the U.S. Supreme Court’s decision in Viking River Cruises, Inc. v. Moriana, ordered Huff’s individual PAGA claims to arbitration and dismissed her nonindividual PAGA claims without prejudice for lack of standing.Huff appealed the October 21, 2022 order, arguing that the trial court erred in dismissing her nonindividual PAGA claims and in finding that she signed the arbitration agreement. The California Court of Appeal, Fourth Appellate District, concluded that Huff timely appealed the October 21 order. On the merits, the court reversed the dismissal of Huff’s nonindividual PAGA claims based on the California Supreme Court’s decision in Adolph v. Uber Technologies, Inc., which rejected Viking River’s interpretation of California law on standing. The court did not address Huff’s arguments concerning the electronic signature, as the reversal based on Adolph rendered it unnecessary.The court remanded the case with directions to stay Huff’s nonindividual PAGA claims pending the completion of arbitration. Huff was awarded her costs on appeal. View "Huff v. Interior Specialists, Inc." on Justia Law

The case involves Taylor Capito, who filed a class action lawsuit against San Jose Healthcare System, LP, also known as Regional Medical Center San Jose, challenging the assessment of Evaluation and Management Services (EMS) fees for two emergency room visits. Capito argued that Regional had a duty to notify emergency room patients about EMS fees beyond listing them in the chargemaster, such as through posted signage or during the patient registration process. She claimed that Regional's failure to do so constituted an unlawful, unfair, or fraudulent business practice under the Unfair Competition Law (UCL) and violated the Consumers Legal Remedies Act (CLRA).The trial court sustained Regional's demurrer without leave to amend, and the Court of Appeal affirmed. The appellate court reasoned that hospitals do not have a duty to disclose EMS fees beyond what is required by the relevant statutory and regulatory framework, following the reasoning in similar cases like Gray v. Dignity Health and Saini v. Sutter Health. The Court of Appeal also affirmed the trial court's order striking the class allegations in Capito's first amended complaint.The Supreme Court of California reviewed the case and affirmed the Court of Appeal's judgment. The court held that hospitals do not have a duty under the UCL or CLRA, beyond their obligations under the relevant statutory and regulatory scheme, to disclose EMS fees prior to treating emergency room patients. The court emphasized that requiring such disclosure would alter the balance of competing interests, including price transparency and the provision of emergency care without regard to cost, as reflected in the multifaceted scheme developed by state and federal authorities. The court also dismissed Capito's appeal from the trial court's order striking her class allegations as moot. View "Capito v. San Jose Healthcare System, LP" on Justia Law

Plaintiff John Doe filed a class action lawsuit against Integris Health, Inc., alleging that Integris collected confidential health information from its website visitors and unlawfully shared it with third parties like Google and Facebook. Doe's complaint, filed in Oklahoma state court, asserted state law claims including negligence, invasion of privacy, and breach of fiduciary duty. Integris removed the case to federal court under the federal officer removal statute, claiming it was acting under the direction of a federal officer by helping the federal government achieve its objective of ensuring patient access to electronic health records (EHR).The United States District Court for the Western District of Oklahoma remanded the case to state court, concluding that Integris had not demonstrated it was "acting under" the direction of a federal officer. The court found that Integris was merely complying with federal regulations, which is insufficient to establish federal officer jurisdiction.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed the district court's decision. The Tenth Circuit held that Integris was not "acting under" a federal officer because it was only complying with federal regulations and not fulfilling a basic government task. The court emphasized that compliance with federal law, even if highly detailed and supervised, does not equate to acting under a federal officer. The court also noted that Integris's use of tracking technology on its website was not required by the federal government and was not part of any federal directive. Therefore, the court concluded that removal under the federal officer removal statute was improper. View "Doe v. Integris Health" on Justia Law