Justia Class Action Opinion Summaries

The plaintiffs, current and former inmates of the Illinois Department of Corrections (IDOC), have been diagnosed with hepatitis C. They filed suit against IDOC, Wexford (which provides inmate health services) and doctors more than 10 years ago after fruitless efforts to receive treatment for their disease while incarcerated. Their 42 U.S.C. 1983 complaint alleges that the diagnostic and treatment protocols for IDOC inmates with hepatitis C violate the Eighth and Fourteenth Amendments.The Seventh Circuit reversed the grant of class certification and vacated a preliminary injunction. After discussing numerosity and commonality of facts and issues, the court noted that the district court failed to name a class representative or explain its omission, leaving no way to assess the adequacy of representation. On the assumption that the court would have accepted the proposed representatives, the record does not reveal whether they would be adequate. The lack of a named representative also makes it impossible to find typicality--that the “claims or defenses of the representative parties are typical of the claims or defenses of the class.” The individual plaintiffs have not shown that they are likely to suffer irreparable harm absent the preliminary injunction, so it was error to grant injunctive relief. View "Orr v. Shicker" on Justia Law

Bennett was assigned to Cook County Jail Division 10, which houses detainees who need canes, crutches, or walkers. He filed suit under the Americans with Disabilities Act, 42 U.S.C. 12131–34, and the Rehabilitation Act, 29 U.S.C.794, alleging that Division 10 lacks grab bars and other necessary fixtures. Bennett claims that he fell and was injured. He unsuccessfully sought to represent a class. The court reasoned that the appropriate accommodation of any detainee’s situation depends on personal characteristics, so common questions do not predominate under FRCP 23(b)(3). Bennett proposed an alternative class to avoid person-specific questions, contending that Division 10, which was constructed in 1992, violates 28 C.F.R. 42.522(b)'s requirement that as of “1988 … construction[] or alteration of buildings” must comply with the Uniform Federal Accessibility Standards. The Standards require accessible toilets to have grab bars nearby and accessible showers to have mounted seats. The district court rejected this proposal, reasoning that to determine whether the Structural Standards control, thereby mooting the reasonable accommodation inquiry, would require a ruling on the merits, which would “run[] afoul of the rule against one-way intervention.”The Seventh Circuit vacated. The "view that a class cannot be certified unless the plaintiff has already prevailed on the central legal issue is a formula for one-way intervention rather than a means to avoid it." Bennett proposes a class that will win if the Standards apply and were violated, to detainees’ detriment and otherwise will lose. View "Bennett v. Dart" on Justia Law

Plaintiffs filed a putative class action alleging that defendants deceived plaintiffs into believing their products were approved by the FDA. After the district court remanded the case back to state court, the Eighth Circuit granted defendants' petition for review under 28 U.S.C. 1453(c)(1), limiting review to the issue of federal question jurisdiction.The court held that federal question jurisdiction exists in this case, because plaintiffs rely explicitly on federal law throughout their pleadings and their prayer for relief invokes federal jurisdiction where it seeks injunctive and declaratory relief that necessarily requires the interpretation and application of federal law, including the Food Drug and Cosmetic Act. Therefore, based on the allegations in the complaint and relief sought, the court found that a federal issue surrounding the state law claims is necessarily raised, actually disputed, substantial, and capable of resolution in federal court without disrupting the federal-state balance approved by Congress. Accordingly, the court vacated and remanded for further proceedings. View "Wullschleger v. Royal Canin U.S.A., Inc." on Justia Law

These consolidated appeals arose from a class action brought by prisoners in the custody of the Arizona Department of Corrections (ADC) against senior ADC officials, challenging ADC's provision of healthcare. At issue on appeal are eleven district court orders imposing contempt sanctions, awarding attorneys' fees to plaintiffs, appointing expert witnesses, and otherwise enforcing the settlement agreement between the parties.The Ninth Circuit affirmed the Contempt Order, the Termination Order, and the HNR-Box Order. The panel vacated the Attorneys' Fees Order and Judgment, remanding with instructions to (a) recalculate the fee award by determining the correct hourly rates for each year, (b) exclude from any fee award the 11 hours erroneously included; (c) modify the costs award down by $1,285.79 in light of the district court's failure to reflect the downward adjustments in its prior order; and (d) reweigh whether a fee enhancement was appropriate without double-counting the Kerr factors. The panel dismissed the remainder of the Medical Needs Appeal for lack of jurisdiction. View "Parsons v. Ryan" on Justia Law

The Landowners filed a “rails-to-trails” class action against the United States, claiming that the government, through the National Trails System Act, effected a Fifth Amendment taking of Landowners’ reversionary rights to property underlying railroad easements owned by the BNSF Railway. On remand, the Claims Court rejected the government’s argument that a negotiated settlement had been abandoned; approved that settlement agreement as procedurally and substantively fair; entered a partial final judgment pursuant to Rule 54(b) “in the total amount of $159,636,521.65, consisting of $110,000,000 in principal and $49,636,521.65 in interest,” and deferred determination on the amount of attorney fees and costs to award class counsel under the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 (URA). The Federal Circuit affirmed, upholding finding that the government failed to meet “its burden of demonstrating that the parties unequivocally intended to abandon the Settlement Agreement.” The court declined to address the government’s argument that the Claims Court erred by not limiting class counsel to the agreed amount of URA fees and costs, concluding that it lacked jurisdiction over the issue. View "Haggart v. United States" on Justia Law

Plaintiff filed suit against the police chief, the city, and other public officials, alleging violations of the Driver's Privacy Protection Act (DPPA). After the police chief admitted liability for six violations of the Act, the jury awarded plaintiff punitive damages. The district court ruled that plaintiff failed to present sufficient evidence that the city was directly liable for the violations, but authorized the jury's finding that the city was vicariously liable for the police chief's actions.The Eighth Circuit affirmed and held that the district court did not abuse its discretion by ruling that plaintiff's proposed class failed to satisfy the numerosity requirement of Federal Rule of Civil Procedure 23(a) and the predominance requirement of Rule 23(b)(3); the district court properly refused to entertain direct liability against the city where the police chief acted for personal reasons, not under the auspices of official policymaking authority, and thus his actions did not represent a policy of the city; the district court correctly construed the civil action provisions of the Act to incorporate background tort-related rules of vicarious liability; the district court did not abuse its discretion in excluding certain evidence at trial; and the district court did not err in declining to award requested costs. The court rejected plaintiff's remaining claims and denied the city's motion to strike portions of plaintiff's appendix and brief. View "Orduno v. Pietrzak" on Justia Law

Three women allege that Memphis failed to submit for testing the sexual assault kits (SAKs) prepared after their sexual assaults. They allege that Memphis possessed over 15,000 SAKS that it failed to submit for testing, resulting in spoliation, and sought to certify a class of women whose kits Memphis failed to test. The district court dismissed with prejudice all of Plaintiffs’ claims except those under the Equal Protection Clause. Two years of discovery apparently cost Memphis over $1 million. Discovery revealed that the SAKs of two plaintiffs were tested soon after their assaults. The third plaintiff’s SAK was submitted for testing 10 years after her 2003 assault. The district court granted Memphis summary judgment as to two plaintiffs and struck the class allegations, finding that no amount of additional discovery would allow Plaintiffs to sufficiently demonstrate commonality. The Sixth Circuit reversed. Plaintiffs were moderately diligent in pursuing discovery, although somewhat blameworthy in relying on the city’s representations that discovery would be forthcoming. Memphis unreasonably delayed producing discovery material and additional discovery might have changed the outcome. Expenditures of time and money alone do not justify terminating discovery where a plaintiff has been diligent and may still discover information that could establish a genuine issue of material fact. View "Doe v. City of Memphis" on Justia Law

The Supreme Court affirmed the order of the district court denying Appellant's motion for postconviction relief following an evidentiary hearing, holding that the district court did not err in denying Appellant's motion for postconviction relief.Appellant pled no contest to first degree assault and tampering with a witness and was sentenced to fifty to fifty years' imprisonment. Following the denial of his direct appeal, Petitioner initiated this postconviction proceeding, alleging that he received ineffective assistance of counsel at both the trial and appellate levels. The district court denied relief. The Supreme Court affirmed, holding that Appellant's claims were either without merit or that Appellant failed to establish prejudice. View "State v. Beehn" on Justia Law

The First Circuit vacated the district court's denial of prison officials' motion for summary judgment on Plaintiff's lawsuit alleging the use of excessive force in violation of the Eighth Amendment, holding that the district court failed to fulfill its obligation to follow the law as set forth in controlling precedent.The prison officials moved for summary judgment arguing that they were entitled to qualified immunity. The district court denied the motion. The record contained two versions of the relevant interaction between Plaintiff and prison officials. Under Scott v. Harris, 550 U.S. 372, 377 (2007), the district court's job was to decide whether the prison officials' evidence blatantly contradicted Plaintiff's version of events. The district court, however, rejected the teaching of Scott and denied the qualified immunity defense. The First Circuit held that the court's denial of qualified immunity was predicated on its error of law and remand to another district court judge for further proceedings consistent with the law was required. View "Underwood v. Barrett" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the judgment of the trial court concluding that Petitioner, who represented a putative class of citizens seeking to strike down state statutes and a city's ordinance authorizing use of red-light cameras as a traffic-enforcement tool, was not required to seek an administrative remedy before filing his case in district court, holding that Petitioner lacked standing to bring one of his claims, that governmental immunity applied to another claim, and that Petitioner was required to seek administrative relief before filing a takings claim in district court.In reversing, the court of appeals concluded that the trial court had no jurisdiction over Petitioner's claims because Petitioner had failed to seek administrative relief. The Supreme Court affirmed but for different reasons, holding (1) Petitioner lacked standing to bring his prospective claims for declaratory and injunctive relief; (2) governmental immunity barred Petitioner's reimbursement claim; (3) Petitioner was required to exhaust his administrative remedies before bringing his constitutional takings claim in district court; and (4) an amended pleading would not cure the defects in Petitioner's claims. View "Garcia v. City of Willis" on Justia Law