Justia Class Action Opinion Summaries

At issue here was national assets stolen by President Ferdinand Marcos. Victims of Marcos' human rights abuses ("Pimentel class") obtained a judgment against Marcos' estate and, in enforcing the judgment, sought to obtain assets also sought by the Republic of the Philippines and its commission organized to retrieve the assets (collectively, Republic). In dispute was the assets of Arelma, a Panamanian corporation, which were held in a brokerage account. The brokerage firm commenced an interpleader action in federal court. The district court awarded ownership of the Arelma assets to the Pimentel claimants. The U.S. Supreme Court reversed, holding that the assertion of sovereign immunity by the Republic required dismissal for lack of a required party. Petitioner then commenced this turnover proceeding seeking to execute the Pimental judgment against the Arelma account. Meanwhile, a Philippine court determined the assets had been forfeited to the Republic. PNB and Arelma moved to intervene, requesting dismissal. Supreme Court denied the motion. The appellate division reversed. The Court of Appeals affirmed, holding that the appellate division did not err in concluding that dismissal was required under N.Y.C.P.L.R. 1001, as the Republic was a necessary party but could not be subject to joinder in light of the assertion of sovereign immunity. View "Swezey v. Merrill Lynch, Pierce, Fenner & Smith, Inc." on Justia Law

Plaintiff-Appellant Arrienne Mae Winzler brought state law claims against Defendant-Appellee Toyota Motor Sales USA, Inc. (Toyota) on behalf of a proposed nationwide class of 2006 Toyota Corolla and Toyota Corolla Matrix owners and lessees. She alleged that the cars harbored defective "Engine Control Modules" ("ECMs"), making them prone to stall without warning. As relief, she asked for an order requiring Toyota to notify all relevant owners of the defect and then to create and coordinate an equitable fund to pay for repairs. Before addressing whether Plaintiff's class should be certified, the district court held her complaint failed to state a claim and dismissed it under Fed. R. Civ. P. 12(b)(6). As Plaintiff began her appeal, Toyota announced a nationwide recall of 2005-2008 Toyota Corolla and Corolla Matrix cars to fix their ECMs. Arguing that these statutory and regulatory processes were exactly the relief sought in Plaintiff's complaint, Toyota asked the Tenth Circuit to find that its recall rendered Plaintiff's case moot. "Because prudential mootness is arguably the narrowest of the many bases Toyota has suggested for dismissal, and because it is sufficient to that task, [the Court has] no need to discuss any of Toyota's other arguments for the same result." The Court vacated the district court's judgment and remanded the case with instructions to dismiss the case as moot. View "Winzler v. Toyota Motor Sales U.S.A., Inc" on Justia Law

Five Medicaid recipients filed a class action against the District, alleging that the District systematically denied Medicaid coverage of prescription medications without providing the written notice required by federal and D.C. law. The district court dismissed the case on the pleadings, concluding that plaintiffs lacked standing to pursue their claims for injunctive and declaratory relief. At least with regard to one plaintiff, John Doe, the allegations sufficiently established injury, causation, and redressability and the court concluded that Doe had standing to pursue his claims for injunctive and declaratory relief. Therefore, the court had no need to decide whether the other plaintiffs had standing and reversed the judgment, remanding for further proceedings. View "NB, et al. v. DC, et al." on Justia Law

This case involved the competitive bidding for an airport advertising concession. After the completion of the bid process, plaintiff - the second-place finisher - brought this action pursuant to 42 U.S.C. 1983, alleging a conspiracy to violate plaintiff's equal protection rights during the bid process. The court concluded that plaintiff's conspiracy claim failed against defendants because the underlying proposed equal protection claim failed, lacking the sufficient identifiable group required. Therefore, the court concluded that the facts and inferences in this case pointed overwhelmingly in favor of defendants. Accordingly, the court vacated the district court's post-verdict order denying judgment as a matter of law and remanded with instructions to grant judgment as a matter of law to defendants. View "Corey Airport Services, Inc. v. Clear Channel Outdoor, Inc." on Justia Law

John Graham, a Canadian citizen, was convicted of felony murder and sentenced to life imprisonment without parole. Graham appealed, raising a number of arguments, including the contention that because he was extradited from Canada on a federal premeditated murder charge, under the specialty doctrine of federal extradition law, the State lacked personal jurisdiction to prosecute him on the State felony murder charge. The Supreme Court affirmed, holding (1) because Canada consented to waive specialty with respect to the state charge at issue, the State had jurisdiction to prosecute Graham for felony murder; (2) the circuit court erred in admitting certain hearsay, but the error was harmless; (3) there was sufficient evidence to sustain a finding of guilt beyond a reasonable doubt; and (4) Graham's life sentence without parole was authorized by statute and was constitutional under the Eighth Amendment. View "State v. Graham" on Justia Law

Defendant Victor Jordan was convicted of reckless endangerment in the first degree. The appellate court affirmed, concluding (1) Defendant's request to represent himself was not clear and unequivocal, and (2) Defendant's right to cross-examine a witness was not improperly restricted. The Supreme Court reversed, holding (1) Defendant in this case clearly and unequivocally asserted his Sixth Amendment right to self-representation, and the trial court's denial of Defendant's request without canvassing him was a violation of that right; and (2) the trial court did not improperly restrict Defendant's cross-examination of the witness. Remanded for a new trial on the charge of reckless endangerment in the first degree. View "State v. Jordan" on Justia Law

A taxpayer class filed an illegal-exaction complaint. The case was remanded for the circuit court to ascertain a remedy consistent with the Supreme Court's decision that the taxpayers had proved a valid claim for illegal exaction of increased ad valorem library taxes for the 2007 ad valorem tax year. In this appeal, the taxpayers contended that the circuit court erred in applying the voluntary-payment rule to class members who paid the tax in question prior to the date the complaint for illegal exaction was filed. The Supreme Court dismissed the appeal without prejudice, holding that the order appealed was not a final order and did not contain specific factual findings of any danger of hardship or injustice that could be alleviated by an immediate appeal, and therefore, the Court lacked jurisdiction over the appeal. View "Robinson v. Villines" on Justia Law

This case stemmed from a class action that began more than a quarter century ago where Idaho state prisoners at the Idaho State Correctional Institution (ISCI) prevailed on their claims that, inter alia, because of deliberate indifference, without any connection to a legitimate penological purpose, the inmates were subjected to needless pain and suffering on account of inadequate medical and psychiatric care. The district court issued an injunction to remedy the constitutional violations and the injunctions remained in effect in 2008 and 2009 when the facts giving rise to this case occurred. The Portland law firm of Stoel Rives, LLP was appointed to represent the prisoner class. At issue on appeal was whether Stoel Rives was entitled to an attorneys' fee award in the class action under the Prison Litigation Reform Act (PLRA), 42 U.S.C. 1997e. The court held that, in this case, the judge had discretion to consider whether Stoel Rives's work on a motion to compel conformity to the injunction was "directly and reasonably incurred in enforcing the relief." The district court acted within the bounds of its discretion in awarding fees in a reasonable amount for bringing about that conformity with the injunction. Here, Stoel Rives's work was what one would expect of a lawyer working for a client that could afford its efforts but that was not indifferent to the cost. The firm showed no evidence of milking the case, and the fees were "directly and reasonably incurred." Accordingly, the court affirmed the judgment. View "Balla v. State of Idaho, et al." on Justia Law

Verizon attached a box to a building that plaintiffs owned and used the box to transmit telephone communications to and from Verizon's customers in other buildings. Plaintiffs claimed that Verizon took their property without paying them just compensation and deceived them into believing that no compensation was owed. The court held that plaintiffs have stated a valid "inverse condemnation" claim for just compensation, and that the claim was not time-barred. However, their claim for an alleged violation of General Business Law 349 was barred by the statute of limitations, and their unjust enrichment claim was legally insufficient. The court also held that the courts below properly denied plaintiffs' motion for class certification. View "Corsello v Verizon N.Y., Inc." on Justia Law

Plaintiffs, nine children in the custody of PMC, filed suit under 42 U.S.C. 1983 against three Texas officials, in their official capacities, seeking to represent a class of all children who were now, and all those who will be, in the State's long-term foster care. The gravaman of plaintiffs' complaint is that various system-wide problems in Texas's administration of its PMC subjected all of the children in PMC to a variety of harms. Applying the standards announced in the Supreme Court's recent opinion, Wal-mart Stores, Inc. v. Dukes, the court held that the district court failed to conduct the "rigorous" analysis required by Rule 23 in deciding to certify the proposed class. The court also held that the district court abused its discretion by certifying a class that lacked cohesiveness under Rule 23(b)(2). Accordingly, the court vacated the district court's class certification order and remanded for further proceedings. View "M.D., et al. v. Rick Perry, et al." on Justia Law