Justia Class Action Opinion Summaries

The City of Los Angeles contracted with PricewaterhouseCoopers (PwC) to modernize the billing system for the Department of Water and Power (LADWP). The rollout in 2013 resulted in billing errors, leading the City to sue PwC in 2015, alleging fraudulent misrepresentation. Concurrently, a class action was filed against the City by Antwon Jones, represented by attorney Jack Landskroner, for overbilling. Discovery revealed that the City’s special counsel had orchestrated the class action to settle claims favorably for the City while planning to recover costs from PwC.The Los Angeles County Superior Court found the City engaged in extensive discovery abuse to conceal its misconduct, including withholding documents and providing false testimony. The court imposed $2.5 million in monetary sanctions against the City under the Civil Discovery Act, specifically sections 2023.010 and 2023.030, which allow sanctions for discovery misuse.The California Court of Appeal reversed the sanctions, interpreting the Civil Discovery Act as not granting general authority to impose sanctions for discovery misconduct beyond specific discovery methods. The appellate court held that sections 2023.010 and 2023.030 do not independently authorize sanctions but must be read in conjunction with other provisions of the Act.The Supreme Court of California reversed the Court of Appeal’s decision, holding that the trial court did have the authority to impose monetary sanctions under sections 2023.010 and 2023.030 for the City’s pattern of discovery abuse. The Supreme Court clarified that these sections provide general authority to sanction discovery misuse, including systemic abuses not covered by specific discovery method provisions. View "City of Los Angeles v. Pricewaterhousecoopers, LLP" on Justia Law

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

Since 1992, the Energy Star Program has set energy efficiency standards for categories of products and permitted approved products to bear the Energy Star logo. Three models of Whirlpool top-loading clothes washers were approved to display that logo and did so from 2009-2010. Under one method of measurement, those machines did not meet the Program’s energy- and water-efficiency standards; the washers did satisfy the Program’s standards under another measurement technique, which the Program previously endorsed. Program guidance from July 2010 disapproved of that method.Consumers in several states who had purchased those models commenced a putative class action against Whirlpool and retailers that sold those machines, alleging breach of express warranty and violations of state consumer protection statutes based on the allegedly wrongful display of the Energy Star logo. The district court certified a class action against Whirlpool but declined to certify a class against the retailers. At summary judgment, the court rejected all remaining claims.The Third Circuit affirmed, finding no genuine dispute of material fact. The plaintiffs did not demonstrate that the models were unfit for their intended purpose. A reasonable jury could not find that the retailer defendants were unjustly enriched from selling the washers. Without evidence of a false or misleading statement attributable to Whirlpool or the retailers, the state consumer protection claims failed. View "Dzielak v. Whirlpool Corp" on Justia Law

Each of the four plaintiffs filed a putative class action complaint in state court, alleging violations of the Magnuson-Moss Warranty Act (MMWA), 15 U.S.C. 2301, claiming that the defendants either concealed written warranties prior to sale or provided warranties that prohibit the use of third-party repair services or parts in violation of MMWA. The defendants removed the actions to the U.S. District Court for the Western District of Pennsylvania pursuant to the Class Action Fairness Act (CAFA), 28 U.S.C. 1332(d)(2).The plaintiffs moved to remand to state court. The district court held that remand was appropriate because MMWA’s jurisdictional requirements were not satisfied and neither CAFA nor traditional diversity jurisdiction can be used to circumvent those jurisdictional requirements. The Third Circuit affirmed.MMWA claims can only be brought in federal court if section 2310(d)(3)’s requirements are satisfied, including that a class action name at least 100 plaintiffs; here, each complaint names only one plaintiff. MMWA’s stringent jurisdictional requirements are irreconcilable with CAFA. Allowing CAFA to govern MMWA class claims would undercut the MMWA’s requirement and allow an MMWA class action to proceed in contravention of the MMWA. View "Rowland v. Bissell Homecare, Inc." on Justia Law

The Supreme Court reversed the judgment of the circuit court denying Plaintiff's motion for class-action certification in her suit against Defendant, a car dealership, holding that the circuit court abused its discretion in denying the motion.Plaintiff filed a class action complaint against Defendant alleging that the "mandatory notice of private or public sale" sent by Defendant repossessing Plaintiff's vehicle and informing her that the vehicle would be sold at a public sale failed to comply with the Uniform Commercial Code and Arkansas law and that the accrued interest rate was unlawful. The circuit court denied Plaintiff's motion for class certification without holding a hearing. The Supreme Court reversed, holding that the circuit court abused its discretion in refusing to certify the class based on the record before it. View "Rivera-Ceren v. Presidential Limousine & Auto Sales, Inc." on Justia Law

In this consolidated action, the Supreme Court held that the trial court did not abuse its discretion in ordering class certification.Plaintiffs, service station operators and franchised dealers for gasoline products supplied by Defendant, a wholesale supplier, commenced this putative class action alleging that the proposed class members had been overcharged. Defendant then commenced a separate action against one of the plaintiffs. In response, that plaintiff filed a counterclaim styled as a proposed class action that mirrored Plaintiffs’ complaint in the earlier action. The trial court solicited the two actions and then allowed the action to proceed as a class action. Defendant appealed from the orders certifying the class. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in ordering class certification. View "Standard Petroleum Co. v. Faugno Acquisition, LLC" on Justia Law

Defendants are the nation’s largest distributors of pre-filled propane exchange tanks, which come in a standard size. Before 2008, Defendants filled the tanks with 17 pounds of propane. In 2008, due to rising prices, Defendants reduced the amount in each tato 15 pounds, maintaining the same price. Plaintiffs, indirect purchasers, who bought tanks from retailers, claimed this effectively raised the price. In 2009, plaintiffs filed a class action alleging conspiracy under the Sherman Act. Plaintiffs settled with both Defendants. In 2014, the Federal Trade Commission issued a complaint against Defendants, which settled in 2015 by consent orders, for conspiring to artificially inflate tank prices. In 2014, another group of indirect purchasers (Ortiz) brought a class action against Defendants, alleging: “Despite their settlements, Defendants continued to conspire, and ... maintained their illegally agreed-upon fill levels, preserving the unlawfully inflated prices." The Ortiz suit became part of a multidistrict proceeding that included similar allegations by direct purchasers (who bought tanks directly from Defendants for resale). The Eighth Circuit reversed the dismissal of the direct-purchaser suit as time-barred, holding that each sale in a price-fixing conspiracy starts the statutory period running again. The court subsequently held that the indirect purchasers inadequately pled an injury-in-fact and lack standing to pursue an injunction to increase the fill levels of the tanks and may not seek disgorgement of profits. View "Ortiz v. Ferrellgas Partners, L.P." on Justia Law

Subject to exceptions, the Song-Beverly Credit Card Act of 1971 (Civ. Code, 1747) generally prohibits a retailer from requesting and recording a customer’s “personal identification information” when the customer is purchasing goods or services with a credit card. Lewis filed a putative class action against Safeway, alleging violation of the Act when Safeway’s clerk requested and recorded Lewis’s date of birth in Safeway’s cash register system when he purchased an alcoholic beverage with a credit card. The trial court held that Safeway’s conduct was exempted by the obligation-imposed-by-law exception. The court of appeal agreed. To satisfy its obligations under the Alcoholic Beverage Control Act, a licensee is obligated to verify the age of a customer purchasing an alcoholic beverage (Bus. & Prof Code, 25658(a), 25659), to keep records of its sales of alcoholic beverages, and to make those records available to the Department of Alcoholic Beverage Control. View "Lewis v. Safeway" on Justia Law

Rahman filed a securities class action against KB, an importer of infant furniture and products, and individuals, alleging violation of Section 10(b) of the Securities Exchange Act and SEC Rule 10b-5 and (2) and Section 20(a) of the Exchange Act. The complaint alleged that defendants misled investors by artificially inflating KB’s stock price by issuing deceptive public financial reports and press releases dealing with compliance with customs laws and overall financial performance. A second amended complaint specified failure to disclose product recalls, safety violations, and illegal staffing practices. The district court dismissed for failure to satisfy the heightened scienter pleading standard required by the Private Securities Litigation Reform Act, 15 U.S.C. 78u-4(b)(2). The Third Circuit affirmed. View "Rahman v. Kid Brands, Inc." on Justia Law

Sam’s Club is a members-only retail warehouse that features a section for clearance items, called “as-is” items. Items may be designated “as-is” for various reasons and may be damaged or undamaged. Every as-is item is marked with an orange sticker; when a cashier scans the item, the original price appears and the cashier must perform a manual override. The software records the fact that a price override was performed, but does not include the reason. Overrides can occur for reasons other than “as-is” designation. Sam’s contracted with NEW to sell extended warranties for items sold in the store. NEW will not cover some “as is” products, including some purchased by Hayes. On each occasion, Sam’s employees offered and Hayes purchased a NEW warranty. The store provided Hayes with a manual and remote missing from a television he purchased and offered to refund the warranty price. Hayes declined. Hayes sued, on behalf of himself and all other persons who purchased a warranty for an as-is product from Clubs in New Jersey since 2004, asserting violation of the state Consumer Fraud Act, breach of contract, and unjust enrichment. The trial court certified a Rule 23(b)(3) class. The Third Circuit vacated and remanded for consideration of Rule 23’s class definition, ascertainability, and numerosity requirements in light of a recent decision. View "Hayes v. WalMart Stores Inc" on Justia Law