Justia Class Action Opinion Summaries

The City of Gridley operates an electric utility and approved reduced electric rates for residential users in September 2020. Plaintiffs, residential ratepayers, challenged these rates, alleging they resulted in charges exceeding the reasonable cost of providing electric service, thus constituting a tax without voter approval in violation of article XIII C of the California Constitution. They also claimed the rates violated the state and federal takings clauses under the unconstitutional conditions doctrine. Plaintiffs sought a writ of mandate and class action complaint, alleging the City set rates higher than necessary and transferred excess revenues to its general fund.The Superior Court of Butte County denied the City’s motion for summary judgment, finding triable issues of fact regarding whether the rates resulted in excessive charges and whether plaintiffs had a property interest in continued electric service. The court rejected the City’s argument that article XIII C was inapplicable because the City did not impose, extend, or increase a tax when it approved reduced rates. The court also found that the unconstitutional conditions doctrine could apply to plaintiffs' takings claim.The California Court of Appeal, Third Appellate District, reviewed the case and concluded that the City was entitled to relief. The court found article XIII C inapplicable because the City did not impose, extend, or increase any tax by reducing its electric rates. The court also found the unconstitutional conditions doctrine inapplicable, as it applies only in the land-use permitting context, not to user fees like the electric rates in question. Consequently, the court directed the trial court to set aside its order denying the City’s motion for summary judgment and to enter a new order granting the motion. The City’s motion for summary judgment was granted, and the stay of proceedings in the trial court was vacated. View "City of Gridley v. Super. Ct." on Justia Law

The case involves a class action lawsuit against the City of Los Angeles, challenging the constitutionality of a $63 late fee imposed for failing to pay a parking meter fine within 21 days. The plaintiffs argue that this late fee, which matches the amount of the original fine, violates the Eighth Amendment's Excessive Fines Clause. The plaintiffs incurred at least one parking meter citation and late fee, and they assert that the late fee is both facially unconstitutional and unconstitutional as applied to individuals who cannot afford to pay it within the specified time frame.The United States District Court for the Central District of California initially granted summary judgment in favor of the City, finding that the $63 parking fine was not "grossly disproportionate" to the offense of overstaying a parking meter. The court also rejected the challenge to the $63 late fee without providing a detailed rationale. The plaintiffs appealed, and the Ninth Circuit previously upheld the initial fine but remanded the case to determine whether the late fee violated the Excessive Fines Clause.The United States Court of Appeals for the Ninth Circuit reversed the district court's summary judgment for the City regarding the late fee. The Ninth Circuit found that a genuine factual dispute exists about the City's basis for setting the late fee at 100 percent of the parking fine. The court noted that the City provided no evidence on how it determined the $63 late fee amount, making it impossible to conclude as a matter of law that the fee is not "grossly disproportional" to the harm caused by the untimely payment. The court declined to incorporate means-testing into the Excessive Fines Clause analysis, rejecting the plaintiffs' argument that the fee should consider individuals' ability to pay. The case was remanded for further proceedings consistent with this opinion. View "PIMENTEL V. CITY OF LOS ANGELES" on Justia Law

Brian Houston, representing a putative class, filed a lawsuit against Maricopa County and Sheriff Paul Penzone, alleging that the County's practice of posting arrestees' photographs and identifying information on its Mugshot Lookup website violated his substantive and procedural due process rights and his right to a speedy public trial. Houston's mugshot and personal details were posted online for three days following his arrest, even though he was never prosecuted. He claimed this caused him public humiliation, reputational harm, and emotional distress.The United States District Court for the District of Arizona dismissed Houston's claims. The court found that the Mugshot Lookup post was not a condition of pretrial detention and that Houston failed to show a cognizable liberty or property interest under state law for his procedural due process claim. The court also dismissed his Sixth Amendment claim, noting that Houston was not prosecuted and thus had no trial.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court's dismissal of Houston's substantive due process claim, holding that Houston sufficiently alleged that the Mugshot Lookup post caused him actionable harm and that the County's transparency justification did not rationally relate to the punitive nature of the post. The court affirmed the dismissal of Houston's procedural due process claim, as he did not demonstrate a protected liberty or property interest under state law. The court also affirmed the dismissal of his Sixth Amendment claim, as Houston was not prosecuted and thus had no right to a speedy trial.The Ninth Circuit concluded that Houston adequately pleaded a substantive due process claim but failed to state claims for procedural due process and Sixth Amendment violations. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "HOUSTON V. MARICOPA COUNTY" on Justia Law

In the wake of George Floyd's death in May 2020, Los Angeles experienced widespread protests. The plaintiffs, including Black Lives Matter Los Angeles and several individuals, filed a class action lawsuit against the City of Los Angeles and then-LAPD Chief Michel Moore. They alleged that the LAPD used excessive force, arrested protestors without probable cause, and restricted their First Amendment rights. The lawsuit sought to certify four classes: a Direct Force Class, an Arrest Class, an Infraction Class, and an Injunctive Relief Class.The United States District Court for the Central District of California certified all four classes. The court found that the plaintiffs had raised common questions about whether LAPD customs or policies caused their injuries. However, the district court did not rigorously analyze whether the damages classes satisfied the commonality requirement under Rule 23(a) or whether common questions predominated over individual ones under Rule 23(b)(3). The court also failed to address whether the Injunctive Relief Class met the commonality requirement under Rule 23(a).The United States Court of Appeals for the Ninth Circuit vacated the district court’s class certification order. The Ninth Circuit held that the district court did not rigorously analyze whether the plaintiffs produced sufficient evidence to meet the class certification requirements. Specifically, the district court did not adequately address the commonality and predominance requirements for the damages classes or identify common questions for the Injunctive Relief Class. The Ninth Circuit remanded the case with instructions for the district court to fully address Rule 23’s class certification requirements. View "BLACK LIVES MATTER LOS ANGELES V. CITY OF LOS ANGELES" on Justia Law

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

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

Anthony Cordero, a student at Montana State University (MSU) during the Spring 2020 semester, sued MSU for prorated reimbursement of his tuition and fees after the university transitioned to online learning due to the COVID-19 pandemic. Cordero claimed that MSU breached an express contract to provide in-person education and services. He also asserted claims for breach of implied contract, unjust enrichment, due process violation, violation of the takings clause, and inverse condemnation.The First Judicial District Court of Lewis and Clark County dismissed four of Cordero’s six claims, including the implied contract and unjust enrichment claims, under M. R. Civ. P. 12(b)(6). The court granted summary judgment in favor of MSU on the remaining claims, including the express contract claim, and denied Cordero’s motion to certify the case as a class action. The court found that Cordero did not identify a specific, bargained-for promise by MSU to provide in-person education and that he had no compensable property interest in the tuition and fees paid.The Supreme Court of the State of Montana reviewed the case and affirmed the lower court's decisions. The court held that there was an express contract between Cordero and MSU, but it did not include a specific promise to provide in-person education. The court found that MSU had the right to change its regulations and policies, including transitioning to online learning during emergencies. The court also affirmed the dismissal of the implied contract and unjust enrichment claims, noting that an implied contract cannot exist when an express contract is present. The court concluded that MSU did not breach its contractual duties regarding tuition and fees, as it maintained campus facilities and services to the extent possible during the pandemic. View "Cordero v. Montana State University" on Justia Law

In the first case, Kent County foreclosed on the homes of Matthew Schafer and Harry and Lilly Hucklebury for unpaid taxes. The properties were sold at auction in 2017, and the county retained the surplus proceeds beyond the owed taxes. Following the Michigan Supreme Court's 2020 decision in Rafaeli, LLC v Oakland Co, which held that retaining surplus proceeds from tax-foreclosure sales is an unconstitutional taking, the Schafer plaintiffs filed a lawsuit seeking those proceeds. The Kent Circuit Court denied the county's motion to dismiss, ruling that Rafaeli applied retroactively. The Court of Appeals affirmed this decision.In the second case, the state of Michigan, acting as the foreclosing governmental unit (FGU) for Shiawassee County, foreclosed on property owned by Lynette Hathon and Amy Jo Denkins in 2018. The state retained the surplus proceeds from the sale. The Hathon plaintiffs filed a class action lawsuit in the Court of Claims, which certified the class and denied the state's motion for summary disposition. After Rafaeli, the plaintiffs moved for summary disposition, and the state moved to revoke class certification. The Court of Claims granted the state's motion to revoke class certification but later recertified an amended class. The Court of Appeals affirmed the Court of Claims' decisions.The Michigan Supreme Court held that Rafaeli applies retroactively to claims not yet final as of July 17, 2020. The court also ruled that MCL 211.78t, which provides a procedure for processing claims under Rafaeli, applies retroactively, while the new two-year limitations period in MCL 211.78l applies prospectively. Claims that arose before December 22, 2020, but expired between that date and the court's decision must be allowed to proceed if filed within a reasonable time. The court affirmed the Court of Appeals' decision in Schafer and remanded the case for further proceedings. In Hathon, the court vacated the Court of Appeals' judgment affirming class recertification and remanded the case to the Court of Claims for reconsideration. View "Schafer v. Kent County" on Justia Law

The case involves two groups of Montgomery residents who were jailed for failing to pay traffic fines. They sued the City of Montgomery, a private contractor (Judicial Correction Services, Inc.), and a lawyer (Branch D. Kloess), alleging that the process of converting fines into jail sentences violated the U.S. Constitution and Alabama law. The plaintiffs sought to certify their claims as class actions, arguing that the City and its contractors systematically failed to conduct proper inquiries into their ability to pay before jailing them.The U.S. District Court for the Middle District of Alabama denied class certification in both cases. The court found that the plaintiffs failed to meet the requirements of Federal Rule of Civil Procedure 23, particularly the predominance and superiority requirements under Rule 23(b)(3). The court concluded that the claims would require individualized inquiries into each probationer's circumstances, such as whether they were given proper hearings and whether the City or its contractors acted wrongfully or in bad faith.The United States Court of Appeals for the Eleventh Circuit reviewed the district court's decision. The appellate court affirmed the lower court's denial of class certification. It agreed that the plaintiffs' claims necessitated individualized proof, making it difficult to resolve the issues on a class-wide basis. The court emphasized that the evidence required to prove the claims, such as records of what happened at individual probation hearings, was not available on a common, class-wide basis. The court also noted that the plaintiffs' claims involved a variety of individual incidents rather than a single, systemic issue that could be addressed collectively.In summary, the Eleventh Circuit held that the district court did not abuse its discretion in denying class certification, as the plaintiffs' claims required individualized inquiries that did not satisfy the predominance requirement of Rule 23(b)(3). The decision to deny class certification was affirmed. View "Carter v. The City of Montgomery" on Justia Law

The case involves a dispute over a protective order issued by the district court, barring Visser and Associates, PLLC (“Visser”) from communicating with potential class members in a putative class action. The case originated from a claim by Wayside Church that Van Buren County had violated the federal Constitution’s Takings Clause by foreclosing on its property to satisfy a tax debt and then selling the property for a higher amount without refunding the difference. The case was revived in federal court following the Supreme Court's overruling of a previous decision that required such claims to be pursued in state court.The district court preliminarily approved a proposed class action settlement between the plaintiffs and defendant counties. Around the same time, Visser began sending solicitation letters to property owners who it thought might have takings claims against counties in the Western District of Michigan. The district court issued a show-cause order, finding that Visser’s solicitation letters did not cross the line from permissible solicitation to misleading, improper communication with potential class members. However, the court was not satisfied with Visser’s explanation for why it had sent solicitation letters to named plaintiffs who were already represented by class counsel.The United States Court of Appeals for the Sixth Circuit affirmed the district court's protective order. The court found that Visser had violated ethical rules by soliciting named plaintiffs and misleading the court. The court also found that Visser had continued to solicit potential class members after the district court had preliminarily approved the class settlement. The court concluded that Visser's conduct posed a serious threat to the fairness of the litigation process and the administration of justice generally. Therefore, the district court did not abuse its discretion in issuing the protective order. View "Wayside Church v. Van Buren County" on Justia Law