Justia Class Action Opinion Summaries

Three individuals filed a class action lawsuit against San Francisco, challenging new water rates adopted by the city’s Public Utility Commission in May 2023. The plaintiffs alleged that the new rates violated Proposition 218 of the California Constitution by including costs unrelated to the actual provision of water service, resulting in charges that exceeded the cost of service. Before adopting the new rates, the city provided required notice to ratepayers, including information about a 120-day period for legal challenges under the applicable validation statutes. The plaintiffs sought a refund, declaratory and equitable relief, and a writ of mandate.After the class action was filed, the City litigated the case for over a year. It participated in discovery, case management, and even moved for summary judgment, without initially arguing that the suit was procedurally improper. Eventually, the City moved for judgment on the pleadings, arguing that plaintiffs’ action was subject to the validation statutes, specifically Government Code section 53759 and Code of Civil Procedure sections 860 et seq., which require reverse validation actions attacking agency matters like water rates to be brought within 120 days and with specific notice by publication to all interested parties. The trial court (San Francisco County Superior Court) agreed with the City, finding the statutes mandatory and jurisdictional, and dismissed the case for failure to comply with the procedural requirements, including timely filing and appropriate notice.On appeal, the California Court of Appeal, First Appellate District, Division Two, reviewed the judgment de novo. The court held that compliance with the validation statutes was mandatory and jurisdictional. Plaintiffs’ failure to file a proper reverse validation action and to provide notice by publication deprived the court of jurisdiction. The court rejected arguments that the City had waived these requirements or that good cause existed for noncompliance. The judgment in favor of the City was affirmed. View "Toy v. City & County of S.F." on Justia Law

Three Venezuelan nationals, alleged by the government to be members of the Tren de Aragua gang, were detained in Texas following a presidential proclamation under the Alien Enemies Act (AEA). This proclamation, issued in March 2025, authorized immediate removal of Venezuelan citizens aged fourteen or older, residing in the United States, who were not naturalized or lawful permanent residents and were identified as members of the gang. The petitioners challenged the proclamation, arguing that it exceeded the President’s authority under the AEA and violated due process rights. They sought class certification and injunctive relief to prevent removal under the AEA.The United States District Court for the Northern District of Texas denied temporary restraining orders and class certification. On appeal, the Fifth Circuit initially dismissed the case for lack of jurisdiction. The Supreme Court, in A.A.R.P. v. Trump, vacated that dismissal and remanded, instructing the Fifth Circuit to address two issues: whether the petitioners were entitled to a preliminary injunction against removal under the AEA, and whether the notice provided for due process claims was sufficient for the putative class. The Supreme Court also allowed the government to remove the petitioners under other lawful authorities.After remand, the three named petitioners were removed from the United States under the Immigration and Nationality Act (INA), not the AEA. The United States Court of Appeals for the Fifth Circuit concluded that, because the petitioners were no longer in the country and no class had been certified, it was impossible to grant any effectual relief. The Fifth Circuit dismissed the appeal as moot for lack of jurisdiction, declining to substitute new class representatives on appeal but leaving open the possibility for future proceedings in the district court. View "W.M.M. v. Trump" on Justia Law

Several individuals arrested in Lancaster County, Pennsylvania, were detained pending trial after cash bail was set at their preliminary arraignments. At these arraignments, which were conducted via video without counsel present, the Magisterial District Judges allegedly imposed bail without considering the defendants’ ability to pay or other required factors under state law. Because they could not afford bail, the plaintiffs remained incarcerated. They brought a class action against four Magisterial District Judges (in their official capacities), Lancaster County, and the Warden of the county prison, alleging violations of their rights to equal protection, due process, and counsel.The United States District Court for the Eastern District of Pennsylvania first dismissed the plaintiffs’ Sixth Amendment claim, holding that the right to counsel attaches at the preliminary arraignment but does not require counsel’s presence at that proceeding, relying on Supreme Court precedent. The District Court later abstained from hearing the equal protection and due process claims under the doctrine established in Younger v. Harris, reasoning that federal intervention would improperly intrude upon ongoing state criminal proceedings and that state courts could address the plaintiffs’ bail-related claims.On appeal, the United States Court of Appeals for the Third Circuit reviewed both rulings. The Third Circuit held that Younger abstention was inappropriate because the plaintiffs did not seek to enjoin ongoing state criminal prosecutions but rather challenged procedures ancillary to those prosecutions—specifically, the process by which bail was set. Therefore, the District Court’s abstention was vacated and the matter remanded for further proceedings on the equal protection and due process claims. However, the Third Circuit affirmed the dismissal of the Sixth Amendment claim, holding that the preliminary arraignment under Pennsylvania law is not a “critical stage” requiring the presence of counsel, even though the right to counsel attaches at that point. View "Hartmann v. Chudzik" on Justia Law

A noncitizen from the Democratic Republic of the Congo was detained in New York pending removal proceedings and was ordered released on bond, which he could not pay. He then brought a class action and habeas petition on behalf of similarly situated noncitizens, challenging government bond-hearing procedures as violating due process. Specifically, he argued that the procedures wrongly placed the burden of proof on detainees, failed to consider ability to pay, and did not require consideration of alternatives to detention.The United States District Court for the Western District of New York initially certified the class and issued a preliminary injunction requiring changes to bond-hearing procedures, with the government complying for nearly two years. After the Supreme Court decided Garland v. Aleman Gonzalez, which held that lower courts lack jurisdiction to issue class-wide injunctive relief under certain immigration statutes, the district court vacated the injunction. It then decertified the class entirely, concluding that neither class-wide injunctive nor declaratory relief was appropriate, and dismissed the case.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the district court did not abuse its discretion in decertifying the class for injunctive relief, as lower courts lack authority for such relief post-Aleman Gonzalez. However, it found that the district court erred by decertifying the class for declaratory relief based on factors irrelevant to the Rule 23(b)(2) class-certification analysis. The Second Circuit clarified that while injunctive relief is unavailable, district courts retain authority to grant class-wide declaratory relief in these cases. Accordingly, the Second Circuit vacated the district court’s judgment and remanded for further proceedings. View "Onosamba-Ohindo v. Ball" on Justia Law

A residential subdivision in Black Hawk, South Dakota, known as Hideaway Hills, was constructed atop land with a history of both underground and surface gypsum mining. The State of South Dakota, through the South Dakota Cement Plant Commission, purchased the property, conducted surface mining, and reclaimed the land to pasture before selling it at public auction, while retaining subsurface mineral rights. Subsequent private owners and developers, aware of prior mining activity, developed the land into residential lots. Years later, residents began experiencing foundational problems and sinkholes, which culminated in a significant sinkhole event in 2020, leading to evacuation and property devaluation.After previous lawsuits against various parties were dismissed, a class action was brought in the Circuit Court of the Fourth Judicial Circuit, Meade County, against the State and related entities. The plaintiffs alleged inverse condemnation, asserting that the State’s reclamation and retention of subsurface rights amounted to a taking or damaging of private property for public use under the South Dakota Constitution. The circuit court granted summary judgment to the State, holding that the plaintiffs’ claims were, in essence, tort claims barred by sovereign immunity.On appeal, the Supreme Court of the State of South Dakota affirmed the circuit court’s decision. The Supreme Court held that the plaintiffs failed to establish a viable inverse condemnation claim because the alleged governmental actions occurred while the State owned the property, and thus did not implicate “private property.” The Court further found that the State’s activities were not for “public use” within the meaning of the state constitution, as the retained mineral rights did not confer a public right of use. The Supreme Court affirmed summary judgment for the State. View "Morse v. State" on Justia Law

Several parents, some acting on behalf of their children, challenged a presidential executive order issued in January 2025. The order declared that children born in the United States to parents who were unlawfully or temporarily present would not be considered “subject to the jurisdiction” of the United States, and therefore would not be entitled to citizenship under the Fourteenth Amendment or the Immigration and Nationality Act. The plaintiffs argued that this order violated both the Constitution and the INA, as it denied citizenship to children based solely on the immigration status of their parents at the time of birth.The United States District Court for the District of New Hampshire reviewed the case and agreed with the plaintiffs. It provisionally certified a nationwide class of children affected by the order and issued a preliminary injunction, blocking enforcement of the executive order. The government appealed, and the Supreme Court of the United States granted certiorari before judgment from the United States Court of Appeals for the First Circuit.The Supreme Court held that children born in the United States to parents who are unlawfully or temporarily present are “subject to the jurisdiction” of the United States, and are entitled to citizenship at birth under the Fourteenth Amendment’s Citizenship Clause. The Court based its holding on the historical understanding of citizenship rooted in the English common law, the repudiation of Dred Scott v. Sandford, and the precedent established in United States v. Wong Kim Ark. The Court affirmed the judgment of the District Court, upholding birthright citizenship for these children. View "Trump v. Barbara" on Justia Law

A group of inmates incarcerated within Alabama’s state prison system filed a class action challenging the adequacy of mental health care provided by the Alabama Department of Corrections (ADOC). The plaintiffs, who suffer from serious mental illnesses, alleged that overcrowding, understaffing, and a series of systemic failures resulted in constitutionally deficient mental health services, contributing to a suicide rate far above the national average. Key alleged deficiencies included improper identification and classification of mental health needs, inadequate treatment plans, insufficient psychotherapy, lack of proper suicide risk management, improper use of segregation for mentally ill inmates, and the imposition of disciplinary sanctions for manifestations of mental illness.The United States District Court for the Middle District of Alabama managed the litigation in multiple phases. After a seven-week bench trial, the court found the ADOC liable under the Eighth Amendment for deliberate indifference to inmates’ serious mental health needs. The court then held extensive remedial proceedings, including further hearings and negotiations, and entered a comprehensive, system-wide remedial injunction. The court made detailed factual findings and, to comply with the Prison Litigation Reform Act (PLRA), issued particularized findings that the relief ordered was necessary, narrowly drawn, and the least intrusive means to remedy the constitutional violations. The court also adopted a monitoring plan to ensure compliance, involving external experts and a transition to internal oversight.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s liability findings and most aspects of the remedial and monitoring orders, holding that system-wide relief was appropriate given the systemic nature of the violations. However, the appellate court reversed certain remedial provisions where it found the relief exceeded what was necessary to correct the constitutional violations, particularly with respect to suicide-proofing cells and some staffing requirements, and as applied to a women’s facility where violations were not established. The case was remanded for modification in those limited respects. View "Braggs v. Commissioner, Alabama Department of Corrections" on Justia Law

A utility company, Southern California Gas (SoCalGas), entered into a 2022 franchise agreement with the City of Los Angeles, allowing it to install, maintain, and operate its natural gas system under city streets. In exchange, SoCalGas agreed to pay the City a franchise fee equal to 5.5% of its gross receipts from natural gas sales within the City. Of this, 3.5% was passed to SoCalGas customers as a surcharge, which was later approved by the California Public Utilities Commission (CPUC). The franchise agreement was adopted after extensive, arm’s-length negotiations and CPUC review.A putative class action was filed by a customer, alleging that the surcharge component of the franchise fee constituted an unlawful tax under article XIII C of the California Constitution because it was not submitted for voter approval. The plaintiff argued the fee should have been apportioned between charges for physical use of city property and charges for the general business privilege, with the latter portion requiring voter approval. The Superior Court for Los Angeles County granted summary judgment for the City, finding the franchise fee, including the surcharge, exempt from voter approval as a charge for the use of local government property under section 1, subdivision (e)(4) of article XIII C.The California Court of Appeal, Second Appellate District, affirmed the trial court’s judgment. The Court held that the franchise fee, including the portion passed through as a surcharge, was not a tax within the meaning of article XIII C, section 1, subdivision (e)(4), because it was compensation for the use of city property and not subject to voter approval. The Court further held that the fee did not need to be apportioned or shown to be reasonably related to the value of the franchise, but found that, even if such a requirement existed, the City met it through bona fide negotiations. View "Nguyen v. City of L.A." on Justia Law

A public agency adopted an ordinance to increase water service rates after following procedural steps, such as conducting a cost-of-service analysis, notifying the public, and holding hearings as required by Proposition 218 of the California Constitution. After adopting the new rates, the agency initiated a validation action in court to confirm the validity of the ordinance, providing notice to interested parties by publication in a local newspaper, as authorized by statute. No one responded to contest the action within the required time, so the court entered default judgment upholding the ordinance.Subsequently, an individual who had previously submitted administrative claims to the agency challenging the rates filed a class action and mandamus lawsuit seeking refunds and declaratory and injunctive relief, alleging violations of Proposition 218 and constitutional rights. The agency responded with a demurrer, arguing that the plaintiff's claims were barred by the prior validation judgment and the statutory scheme requiring such challenges be brought through validation procedures. The Marin County Superior Court agreed, sustaining the demurrer without leave to amend and finding that the plaintiff's opportunity to challenge the rates had been foreclosed by the unchallenged validation judgment.The California Court of Appeal, First Appellate District, Division One, reviewed the case. The court held that under Government Code section 53759 and the related validation statutes, any legal challenge to ordinances adopting water service fees must be brought through specified validation proceedings, including constitutional claims. Since the plaintiff neither intervened in the agency's validation action nor filed a timely reverse validation action, her claims were barred. The court also found that due process was satisfied by the published notice required by statute, and that mandamus proceedings are not exempt from these requirements. The appellate court affirmed the judgment in favor of the agency. View "Hiller v. Marin Municipal Water Dist." on Justia Law

Several researchers at the University of California received multi-year federal grants from agencies including the Environmental Protection Agency, the National Science Foundation, and the National Endowment for the Humanities. In April 2025, these agencies terminated the research grants by issuing form letters, citing shifts in agency priorities and referencing multiple Executive Orders issued by the President, some of which explicitly aimed to eliminate diversity, equity, and inclusion (DEI) and related initiatives from the federal government. The affected researchers alleged these terminations resulted in lost funding, harm to their reputations, and disruption to their projects, with no ready alternative sources of support.The researchers filed a class action lawsuit in the United States District Court for the Northern District of California, asserting constitutional and statutory claims, including violations of the First Amendment and the Administrative Procedure Act (APA). The district court provisionally certified two classes: one consisting of researchers whose grants were terminated by form letter without grant-specific explanation (the Form Termination Class), and another whose grants were terminated specifically due to the DEI Executive Orders (the DEI Termination Class). The district court granted a preliminary injunction, ordering the reinstatement of the grants for both classes. The government appealed.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the plaintiffs had established Article III standing. It reversed the preliminary injunction for the Form Termination Class, concluding that the district court likely lacked jurisdiction over their APA claim because the claim was essentially contractual and thus barred by the Tucker Act. However, the Ninth Circuit affirmed the preliminary injunction for the DEI Termination Class, finding that the class was likely to succeed on its First Amendment claim because the grant terminations were based on viewpoint discrimination. The court remanded for further proceedings. View "THAKUR V. TRUMP" on Justia Law