Justia Class Action Opinion Summaries

Plaintiffs, three plaintiff-classes and Sheila Perdue individually, brought a class action complaint seeking declaratory and injunction relief alleging violations of their federal statutory and constitutional rights. Plaintiffs challenged the Indiana Family and Social Services Administration's (FSSA) automated system of processing claims for Medicaid, Food Stamps, and Temporary Assistance to Needy Families benefits. The trial court held (1) the FSSA's denial notices satisfied due process; (2) the FSSA could not deny an application for Food Stamp benefits when the applicant failed to cooperate in the eligibility determination process; and (3) determined that the FSSA had failed to accommodate Perdue's disabilities in violation of the Americans with Disabilities Act and the Rehabilitation Act. The Supreme Court reversed in part and affirmed in part, holding (1) the FSSA's denial notices were insufficiently explanatory in violation of due process; (2) the FSSA may deny an application for Food Stamp benefit when the applicant fails to cooperate in the eligibility determination process; and (3) Perdue was entitled to reasonable accommodations in applying for benefits, but that did not necessarily require providing a caseworker or case management services. View "Perdue v. Gargano" on Justia Law

Plaintiff Bruce Roger Mills, individually and on behalf of those similarly situated, appealed a judgment that dismissed his claims against the City of Grand Forks to recover the amount of fines and fees collected in the past for noncriminal traffic violations by the City exceeding the amount the City could legally impose under state law. The City cross-appealed that judgment. In 2004, a Grand Forks police officer cited Plaintiff with careless driving. Under Grand Forks City Code, the maximum fine for violation of a noncriminal offense was $1,000 "in the discretion of the court." Plaintiff pled not guilty and proceeded to trial in municipal court. Plaintiff was found guilty. The municipal court imposed against Plaintiff "a fine in the amount of $151 with $0 suspended" and a hearing fee of $15. Plaintiff appealed to district court for a new trial; the court affirmed the conviction and the fine and fees totaling $166. Plaintiff appealed to the Supreme Court, but on December 1, 2004, the Court dismissed the appeal because the district court judgment was "not appealable under N.D.C.C. 39-06.1-03(5)." On August 16, 2010, Plaintiff brought a "Class Action Complaint for Restitution" in state district court seeking the amount of monies paid to Grand Forks exceeding the state law limits for fines for similar state offenses. Plaintiff asserted the excess fines, fees and charges were "involuntary and void." The City argued Plaintiff's claims were precluded by both res judicata and collateral estoppel based on the prior federal court action, and by res judicata because Mills failed to challenge the City's fine scheme in the 2004 state court proceedings. Because the district court correctly ruled Plaintiff's claims were thus barred by res judicata, the Supreme Court affirmed the judgment. View "Mills v. City of Grand Forks" on Justia Law

This case arose when plaintiffs filed a class action complaint under 42 U.S.C. 1983, alleging that the District was violating the Medicaid Act, 42 U.S.C. 1396 et seq. Since 1993, a consent decree has governed how the District provides "early and periodic screening, diagnostic, and treatment services" under the Act. The District has now asked the district court to vacate that decree on two grounds: that an intervening Supreme Court decision has made clear that plaintiffs lack a private right of action to enforce the Medicaid Act, and that in any event, the District has come into compliance with the requirements of the Act. Because the court concluded that the district court's rejection of one of the District's two arguments did not constitute an order "refusing to dissolve [an] injunction[]" within the meaning 28 U.S.C. 1292(a)(1), the court dismissed the appeal for lack of jurisdiction. View "Salazar, et al. v. DC, et al." on Justia Law

As a consequence of a June 2006 storm, the stormwater drainage and storage system (including the wastewater treatment facility) at the Lake Charles refinery of Defendant CITGO Petroleum Company (CITGO), was filled beyond available capacity and overflowed, resulting in a major oil spill. Over 21 million gallons of waste, including 17 million gallons of contaminated wastewater and 4.2 million gallons of slop oil, escaped from the two existing wastewater storage tanks into an area around the tanks which was surrounded by levees or dikes. The oil spill, which was described at trial as "major" and "catastrophic," eventually contaminated over 100 miles of shoreline along the Calcasieu River, and required several months to clean up. Fourteen plaintiffs, employees of Ron Williams Construction (RWC) working at the Calcasieu Refining Company (CRC) south of the CITGO refinery, filed suit against CITGO and R&R Construction, Inc. (R&R) alleging various injuries due to their exposure to noxious gases emanating from the spill. CITGO and R&R stipulated that they were liable for the spill and agreed to pay plaintiffs for all their compensatory damages assessed to CITGO and R&R. After a two week bench trial, the district court ruled that plaintiffs had proved their injuries were caused by CITGO's admitted negligence in allowing the spill. The court of appeal affirmed, holding that the district court's finding the spill caused plaintiffs' injuries was not an abuse of discretion. The Supreme Court granted review of this case to determine whether the courts below erred as to the allocation of fault, in awarding damages for fear of future injury, and in awarding punitive damages. In sum, the Court held that Louisiana's conflict of laws statutes did not provide for the application of the punitive damages laws of Texas or Oklahoma under the facts of this case, that plaintiffs proved that their damages were caused by their exposure to toxic chemicals contained in the oil spill, that plaintiffs are entitled to damages for fear of contracting cancer, and that CITGO did not produce at the hearing on summary judgment factual support sufficient to establish that it would be able to satisfy its evidentiary burden of proof at trial. The Court affirmed in part, and reversed in part. The case was remanded for further proceedings. View "Arabie v. CITGO Petroleum Corp." on Justia Law

Defendant William Coleman was serving a fifteen-year sentence following his convictions on charges pertaining to his relationship with his ex-wife when he went on a hunger strike. Following a trial, the trial court granted the former commissioner of correction's application for a permanent injunction authorizing the department of correction to restrain and force-feed Defendant to prevent life-threatening dehydration and malnutrition. Defendant was subsequently force-fed. The Supreme Court affirmed, holding that the trial court properly determined (1) the state's interests outweighed Defendant's common-law right to bodily integrity; (2) the forcible administration of artificial nutrition and hydration to Defendant did not violate his constitutional right to free speech and privacy; and (3) international law did not prohibit medically necessary force-feeding under such circumstances. View "Comm'r of Corr. v. Coleman" on Justia Law

Leslie Roberts pleaded no contest to one count of rape and was found guilty by the district court. Roberts' crimes subjected him to a life sentence with a mandatory minimum of twenty-five years in prison under Jessica's Law. The district court denied Roberts' motion for a departure and sentenced him to a life sentence with a mandatory minimum of twenty-five years in prison along with lifetime postrelease supervision. For the first time on appeal, Roberts argued that both aspects of his sentence violated his constitutional rights against cruel and unusual punishment. The Supreme Court affirmed, holding (1) the cruel and unusual punishment claim was not preserved for appellate review; and (2) the district court did not abuse its discretion by denying the departure motion. View "State v. Roberts" on Justia Law

This case was remanded to the district court for determination of whether a class should be certified and for determination of what, if any, part of the City's franchise fees for gas and electricity services are related to its administrative expenses in exercising its police power. The district court certified a class, found the franchise fees cannot exceed $1,575,194 per year for the electric utility and $1,574,046 for the gas utility, entered judgment in favor of the certified class against the City in the amount by which such fees exceeded that amount for an approximately ten-year period, and retained jurisdiction to determine the amount of money to be refunded to members of the class. The Supreme Court affirmed the judgment as modified, concluding that certain amounts allocated or not allocated by the district court as proper components of the franchise fees should be modified. Remanded. View "Kragnes v. City of Des Moines" on Justia Law

Plaintiff represented a class of legal immigrants in the state of Washington adversely affected by its recent termination of a state-funded food assistance program for legal immigrants, which exclusively benefitted Washington resident aliens who became ineligible for federal food stamps following the enactment of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996, 8 U.S.C. 1601 et seq. Plaintiff contended that the state, by eliminating food assistance to class members while continuing to administer federal food assistance to U.S. citizens and certain qualified aliens, violated the Fourteenth Amendment's Equal Protection Clause and, by failing to provide class members adequate pre-deprivation notice and opportunity to be heard, also violated the Fourteenth Amendment's Due Process Clause. Because plaintiff failed even to allege that the State treated her less favorably than a similarly situated citizen of the State, her claim of alienage discrimination failed on the merits. The court agreed with the State that plaintiff lacked the concrete and particularized interest required for standing to claim a procedural due process violation. Consequently, plaintiff either lacked standing or would not succeed on the merits of her claims. Therefore, the court reversed the district court's order granting the motion for a preliminary injunction, vacated the injunction, and remanded for further proceedings. View "Pimentel v. Dreyfus, et al." on Justia Law

Appellant was charged with complicity to commit assault in the first degree, attempted burglary in the first degree, and tampering with physical evidence in a juvenile proceeding. Appellant was sixteen years old at the time. The district court found there was no probable cause to believe Appellant had used a firearm in the commission of the offenses under Ky. Rev. Stat. 635.020(4) and therefore declined to order transfer of Appellant to circuit court as a youthful offender. The Commonwealth filed a petition for a writ of mandamus, asking the circuit court to order the district court to transfer Appellant as a youth offender. The circuit court granted the writ, and the court of appeals affirmed. The Supreme Court affirmed, holding that the writ of mandamus issued by the circuit court was not an abuse of discretion where (1) a crime committed by complicity can fall under the mandatory transfer provision of section 635.020(4), and complicity to commit an offense involving use of a firearm requires transfer when an offense involving direct use of a firearm would; and (2) the district court erred in finding that a firearm was not used in Appellant's offense. View "K.R. v. Commonwealth" on Justia Law

The issue on appeal in this case came from the dismissal of a putative class action filed in a California district court. The dismissal was based on a Massachusetts federal district court's final judgment certifying a nationwide class and approving a class settlement. A class member appeared through counsel as an objector in the Massachusetts case filed the present suit in California seeking to represent a nationwide class. The California complaint sought damages based in large part on the same facts alleged in the Massachusetts case, but against different defendants. The putative class was part of the same class certified in the Massachusetts case. The California defendants moved to dismiss the case based on a covenant not to sue contained in the settlement and final judgment entered in the Massachusetts case. Under that provision, the class members, including the member who filed the California suit as the named plaintiff, not only released their claims against the Massachusetts defendants but also agreed not to sue "any other person seeking to establish liability based, in whole or in part," on the claims released. The district court held that the covenant was enforceable against the named plaintiff in the California case, declined to appoint or allow a new class representative because no class had been certified, did not decide whether the covenant was enforceable against the absent members of the putative class, and dismissed. The named plaintiff appealed. Upon review, the Ninth Circuit affirmed. View "Skilstaf, Inc. v. CVS Caremark Corp." on Justia Law