Justia Class Action Opinion Summaries

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

Annalycia Jenkins, a former employee of Dermatology Management, LLC, filed a class action lawsuit against her employer after resigning. She alleged unfair competition, and the employer sought to compel arbitration based on an agreement Jenkins signed on her first day of work. The trial court denied the motion to compel arbitration, finding the agreement both procedurally and substantively unconscionable.The San Luis Obispo County Superior Court found the arbitration agreement substantively unconscionable due to its lack of mutuality, shortened statute of limitations, unreasonable discovery restrictions, and requirement for the parties to equally share the arbitrator’s fees and costs. Procedurally, the court noted the agreement was a contract of adhesion, pre-signed by the employer months before Jenkins was hired, and presented to her on a take-it-or-leave-it basis without the presence of the Chief People Officer.The California Court of Appeal, Second Appellate District, Division Six, reviewed the case de novo and affirmed the lower court’s decision. The appellate court agreed that the arbitration agreement was procedurally unconscionable due to the inequality of bargaining power and the pre-signed nature of the agreement. It also upheld the finding of substantive unconscionability, noting the lack of mutuality, the unreasonable one-year statute of limitations, the unfair cost-sharing provision, and the restrictive discovery terms. The court concluded that the trial court did not abuse its discretion in refusing to sever the unconscionable provisions, as doing so would condone an illegal scheme and incentivize employers to draft one-sided agreements. The order denying the motion to compel arbitration was affirmed. View "Jenkins v. Dermatology Management, LLC" on Justia Law

In this case, two organizations and four individuals brought an action under 42 U.S.C. § 1983 against the City of Phoenix and several police officers, alleging violations of their constitutional rights during a protest outside a rally held by then-President Trump at the Phoenix Convention Center on August 22, 2017. The plaintiffs claimed that the police used excessive force and violated their First, Fourth, and Fourteenth Amendment rights by dispersing the protesters with tear gas, chemical irritants, and flash-bang grenades.The United States District Court for the District of Arizona certified two classes and granted summary judgment to the defendants on all claims except for the individual Fourth Amendment excessive-force claims asserted by three plaintiffs against certain officers. The court found that there was no "seizure" of the class members under the Fourth Amendment and evaluated the excessive-force claims under the Fourteenth Amendment's "shocks-the-conscience" test. The court also granted summary judgment to the defendants on the First Amendment claims, finding no evidence of retaliatory intent.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's summary judgment for the defendants on the class claims. The Ninth Circuit agreed that the use of airborne and auditory irritants did not constitute a "seizure" under the Fourth Amendment and that the Fourteenth Amendment's "purpose to harm" standard applied. The court found no evidence of an improper purpose to harm by the officers.The Ninth Circuit reversed the district court's denial of summary judgment to the individual defendants on the excessive-force claims asserted by the three plaintiffs, holding that the officers were entitled to qualified immunity. The court found that the officers acted reasonably under the circumstances or did not violate clearly established law. The court also affirmed the district court's summary judgment for the individual defendants on the First Amendment claims, finding that the officers had objectively reasonable grounds to disperse the crowd due to a clear and present danger.Finally, the Ninth Circuit affirmed the district court's summary judgment for Police Chief Williams and the City of Phoenix, concluding that there was no evidence that Williams caused or ratified the use of excessive force or that the City was deliberately indifferent to the plaintiffs' constitutional rights. View "PUENTE V. CITY OF PHOENIX" on Justia Law

The case involves a class action lawsuit against Bojangles’ Restaurants, Inc. by several plaintiffs who allege that the company required them to perform unpaid off-the-clock work and made unauthorized edits to their time records. The plaintiffs, who worked as shift managers, claim that Bojangles violated its own policies and the Fair Labor Standards Act (FLSA) by not compensating them for all hours worked, including overtime.The United States District Court for the Western District of North Carolina conditionally certified a collective action for the FLSA claims and later certified class actions for state wage-and-hour law claims in North Carolina and South Carolina. The district court found that the proposed classes met the requirements for numerosity, commonality, and predominance under Federal Rule of Civil Procedure 23. The court relied on the fact that most class members worked opening shifts and were subject to Bojangles’ Opening Checklist, which allegedly required pre-shift work. The court defined the classes broadly to include all shift managers who worked at Bojangles in North Carolina or South Carolina within three years of the complaint.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s certification order. The appellate court found that the district court abused its discretion by employing an overly general approach in identifying the policies that allegedly unified the class members’ claims and by creating overly broad class definitions. The Fourth Circuit held that the district court failed to provide specific evidence of a common policy that mandated off-the-clock work and time-record edits for all class members. The court vacated the certification order and remanded the case for further proceedings, instructing the district court to refine the class definitions and ensure that common questions predominate over individualized issues. View "Stafford v. Bojangles' Restaurants, Inc." on Justia Law

Edgar Gonzalez worked for Nowhere Santa Monica, one of ten related LLCs operating Erewhon markets in Los Angeles. As a condition of his employment, he signed an arbitration agreement with Nowhere Santa Monica. Gonzalez later filed a class action lawsuit against all ten Nowhere entities, alleging various Labor Code violations. He claimed that all entities were his joint employers, sharing control over his employment conditions.The Superior Court of Los Angeles County granted the motion to compel arbitration for Nowhere Santa Monica but denied it for the other entities, finding no evidence that Gonzalez's claims against the non-signatory entities were intertwined with his claims against Nowhere Santa Monica. Gonzalez then dismissed his complaint against Nowhere Santa Monica, and the other entities appealed.The California Court of Appeal, Second Appellate District, reviewed the case. The court held that Gonzalez was equitably estopped from avoiding arbitration with the non-Santa Monica entities because his claims against them were intimately founded in and intertwined with his employment agreement with Nowhere Santa Monica. The court reasoned that Gonzalez's joint employer theory inherently linked his claims to the obligations under the employment agreement, which contained an arbitration clause. Therefore, it would be unfair for Gonzalez to claim joint employment for liability purposes while denying the arbitration agreement's applicability.The appellate court reversed the lower court's order denying the motion to compel arbitration for the non-Santa Monica entities, concluding that all of Gonzalez's claims should be arbitrated. View "Gonzalez v. Nowhere Beverly Hills LLC" on Justia Law

Lawanda Small, a beneficiary and additional insured of her deceased husband's Allianz life insurance policy, filed a class action lawsuit against Allianz Life Insurance Company. She alleged that Allianz violated California Insurance Code sections 10113.71 and 10113.72 by failing to comply with notice procedures required to prevent policies from lapsing due to nonpayment of premiums. Small sought to represent two subclasses: the "Living Insured Subclass" seeking equitable relief to reinstate life insurance coverage, and the "Beneficiary Subclass" seeking damages from death benefits where the insured was deceased.The United States District Court for the Central District of California certified the class, finding that both subclasses satisfied the requirements of Federal Rule of Civil Procedure 23(a) and 23(b). The court granted summary judgment for Small and the class on their breach of contract and declaratory relief claims, ruling that Allianz improperly lapsed the policies by failing to comply with the Statutes. Allianz appealed, arguing that the district court erred in certifying the class and that the summary judgment orders violated the one-way intervention prohibition.The United States Court of Appeals for the Ninth Circuit reversed the district court's order certifying the class and vacated the summary judgment orders. The appellate court held that to recover for alleged violations of the Statutes, plaintiffs must show not only that the insurer violated the notice requirements but also that the violation caused them harm. The court found that individual questions of causation and injury predominated over common questions, making class certification inappropriate. Additionally, the court determined that Small was not an adequate representative with typical questions to represent both subclasses. The case was remanded for further proceedings. View "Small v. Allianz Life Insurance Co. of North America" on Justia Law

In 2021, New Jersey enacted the Cannabis Regulatory, Enforcement Assistance, and Marketplace Modernization Act (CREAMMA), which prohibits employers from refusing to hire job applicants based on cannabis use. In 2022, a retailer rescinded a job offer to an applicant, Erick Zanetich, after he tested positive for cannabis. Zanetich filed a lawsuit claiming the retailer's action violated CREAMMA and public policy. He sought redress individually and on behalf of a putative class.The United States District Court for the District of New Jersey dismissed both counts of Zanetich's complaint. The court found that CREAMMA does not imply a private remedy for violations of its employment protections and that New Jersey's public policy exception to at-will employment does not apply to job applicants. Zanetich appealed the decision.The United States Court of Appeals for the Third Circuit reviewed the case de novo and affirmed the District Court's judgment. The Third Circuit held that CREAMMA does not imply a private remedy for job applicants who fail drug tests for cannabis. The court applied New Jersey's modified Cort test and found that CREAMMA does not confer a special benefit on job applicants, there was no legislative intent to provide a private remedy, and implying such a remedy would not advance CREAMMA's purposes. Additionally, the court held that New Jersey's public policy exception to at-will employment, as established in Pierce v. Ortho Pharmaceutical Corp., does not extend to job applicants. The court also declined to certify the state-law issues to the New Jersey Supreme Court, finding no significant uncertainty or importance warranting certification. View "Zanetich v. WalMart Stores East Inc" on Justia Law

The case involves a class action lawsuit filed by transgender women prisoners in Illinois, who allege that the Illinois Department of Corrections (IDOC) has been deliberately indifferent to their gender dysphoria, a serious medical condition. The plaintiffs seek injunctive relief to ensure timely evaluations and treatments, including hormone therapy, gender-affirming surgery, and appropriate support for social transitioning.The United States District Court for the Southern District of Illinois initially issued a preliminary injunction on February 7, 2022, which was intended to address the plaintiffs' claims. The court later issued further injunctions to supplement and modify the terms. However, more than a year and a half after the preliminary injunction was issued, the district court retroactively labeled it as a permanent injunction and issued a final judgment consistent with the February 7, 2022 decision. The defendants appealed several injunctions and a finding of civil contempt by the district court.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that the district court's attempt to retroactively transform the preliminary injunction into a permanent one was not authorized. The appellate court held that under the Prison Litigation Reform Act (PLRA), the preliminary injunction issued on February 7, 2022, expired 90 days later, on May 8, 2022. Consequently, the appellate court vacated all existing injunctions and remanded the case for further proceedings consistent with its opinion. The court also dismissed the portion of the appeal challenging the finding of contempt, as the district court had not yet imposed any sanctions, which are necessary to establish appellate jurisdiction. View "Monroe v. Bowman" on Justia Law

The City of Rittman filed an original action in prohibition against Judge Corey E. Spitler of the Wayne County Common Pleas Court. Rittman sought to prevent Judge Spitler from exercising jurisdiction over a class-action lawsuit in which Rittman was named as a defendant. The lawsuit, filed by Tara Boler and Trista Bise, alleged that Rittman had illegally collected a 0.5 percent income tax increase beyond its authorized period and sought refunds for the overcharged taxes from 2008 to 2022.In the Wayne County Common Pleas Court, Judge Spitler denied Rittman’s motion to dismiss and motion to stay discovery, and he established a case-management schedule. Rittman then sought a writ of prohibition from the Supreme Court of Ohio to stop Judge Spitler from proceeding with the case, arguing that the lawsuit was an impermissible attempt to bypass the statutory process for obtaining tax refunds.The Supreme Court of Ohio reviewed the case and determined that Judge Spitler had jurisdiction and statutory authority under R.C. 2723.01 to hear the case. The court found that the plaintiffs' claims were substantively governed by R.C. 2723.01, which allows common pleas courts to enjoin the illegal levy or collection of taxes and entertain actions to recover them when collected. The court concluded that although the plaintiffs did not explicitly invoke R.C. 2723, their claims fit within its scope. Therefore, the Supreme Court of Ohio denied the writ of prohibition, allowing Judge Spitler to continue exercising jurisdiction over the underlying case. View "State ex rel. Rittman v. Spitler" on Justia Law