Justia Class Action Opinion Summaries

Upon rehearing in this case involving issues related to an automated traffic enforcement (ATE) system, the Supreme Court concluded that the district court properly granted summary judgment in favor of Defendants, the City of Cedar Rapids and Gatso USA, Inc., holding that Plaintiffs’ challenges to the ATE system were unavailing.The City enacted an ordinance designed to authorize and implement the establishment of an ATE system and contracted that Gatso to install the system. Plaintiffs filed a class-action petition against Defendants claiming, among other things, that the ATE system as implemented violated the equal protection, due process, and privileges and immunities clauses of the Iowa Constitution and that the ordinance as implemented unconstitutionally delegated governmental power to a private entity. The district court granted summary judgment in favor of Defendants. The Supreme Court originally affirmed in part and reversed in part and then vacated its earlier opinion and granted the City’s petition for rehearing. On review, the Court held that it relied on an incorrect version of the City’s ATE ordinance in discussing the issue of preemption and then concluded that the district court did not err in granting summary judgment in favor of Defendants. View "Behm v. City of Cedar Rapids" on Justia Law

Washington public school teachers filed a class action to order the Director of DRS to return interest that was allegedly skimmed from their state-managed retirement accounts. The Ninth Circuit reversed the district court's denial of a stipulated motion to certify a class and dismissal of the action as prudentially unripe. The panel held that the district court erred in dismissing the teachers' takings claim as prudentially unripe because DRS's withholding of the interest accrued on the teachers' accounts constitutes a per se taking to which the prudential ripeness test in Williamson County Regional Planning Commission v. Hamilton Bank of Johnson City, 473 U.S. 172 (1985), did not apply.In regard to the Director's alternative grounds for summary judgment, the panel held that plaintiffs stated a takings claim for daily interest withheld by the Director; the panel clarified that the core property right recognized in Schneider v. California Department of Corrections, 151 F.3d 1194 (9th Cir. 1988), covered interest earned daily, even if payable less frequently; plaintiffs' takings claim was not barred by issue preclusion or by the Rooker-Feldman doctrine; and the takings claim was not foreclosed by the Eleventh Amendment. The panel also held that the district court erred in denying the motion for class certification. Accordingly, the panel remanded for further proceedings. View "Fowler v. Guerin" on Justia Law

Wheelchair-using detainees sued Cook County, alleging violations of the Americans with Disabilities Act and the Rehabilitation Act, based on purportedly inaccessible ramps and bathroom facilities at six county courthouses. The district court certified a class for purposes of injunctive relief. The named plaintiffs also sought damages individually for the same alleged violations. The district court held an evidentiary hearing on the equitable claims and entered a permanent injunction, finding that the defendants had violated the ADA. Relying largely on the same findings, the court granted the plaintiffs partial summary judgment on liability in their personal damage actions, then submitted the question of individual damage awards to a jury. The Seventh Circuit vacated in part. The district court improperly relied on its own findings of fact when it granted partial summary judgment to the plaintiffs on their damage claims. When equitable and legal claims are joined in a single suit, common questions of fact should be tried first to a jury unless there are extraordinary circumstances or an unequivocal waiver by all parties of their jury trial rights. The court upheld the class certification. View "Lacy v. Cook County, Illinois" on Justia Law

The Court of Chancery initially found that Wal-Mart stockholders who were attempting to prosecute derivative claims in Delaware could no longer do so because a federal court in Arkansas had reached a final judgment on the issue of demand futility first, and the stockholders were adequately represented in that action. But the derivative plaintiffs in Delaware asserted that applying issue preclusion in this context violated their Due Process rights. The Delaware Supreme Court surmised this dispute implicated complex questions regarding the relationship among competing derivative plaintiffs (and whether they may be said to be in “privity” with one another); whether failure to seek board-level company documents renders a derivative plaintiff’s representation inadequate; policies underlying issue preclusion; and Delaware courts’ obligation to respect the judgments of other jurisdictions. The Delaware Chancellor reiterated that, under the present state of the law, the subsequent plaintiffs’ Due Process rights were not violated. Nevertheless, the Chancellor suggested that the Delaware Supreme Court adopt a rule that a judgment in a derivative action could not bind a corporation or other stockholders until the suit has survived a Rule 23.1 motion to dismiss The Chancellor reasoned that such a rule would better protect derivative plaintiffs’ Due Process rights, even when they were adequately represented in the first action. The Delaware Supreme Court declined to adopt the Chancellor’s recommendation and instead, affirmed the Original Opinion granting Defendants’ motion to dismiss because, under the governing federal law, there was no Due Process violation. View "California State Teachers' Retirement System, et al. v. Alvarez, et al." on Justia Law

The Supreme Court affirmed the judgment of the motion court overruling Appellant’s motion for postconviction relief under Rule 29.15, holding that Appellant’s argument that his appellate counsel was ineffective was unavailing.Appellant was convicted of second-degree murder. On appeal, appellate counsel did not raise as points of error the trial court’s rejections of Appellant’s requested jury instructions. In his Rule 29.15 motion for postconviction relief, Appellant argued that his appellate counsel was ineffective for failing to raise these issues. The motion court denied the motion. The Supreme Court affirmed, holding that appellate counsel’s performance was not constitutionally deficient because appellate counsel did not fail to exercise the customary level of skill and diligence of a reasonably competent attorney. View "Meiners v. State" on Justia Law

Private indirect purchasers of prescription Flonase filed a class action, alleging that GSK had filed sham petitions with the FDA to delay the introduction of generic Flonase and force them to pay more for Flonase than they would have if the generic version were available. Those plaintiffs moved for final approval of settlement after the court certified the class and approved the notice to settlement class members. Louisiana, an indirect Flonase purchaser, qualified as a potential class member but did not receive the notice; it only received a Class Action Fairness Act (CAFA) Notice, for “the appropriate State official of each State in which a class member resides,” 28 U.S.C. 1715(b) The settlement “permanently enjoined” all members of the settlement class, including Louisiana, from bringing released claims against GSK, even in state court. In an ancillary suit, GSK moved to enforce the settlement against the Louisiana Attorney General. The Third Circuit affirmed denial of the request, finding that under the Eleventh Amendment “a State retains the autonomy to choose ‘not merely whether it may be sued, but where it may be sued.'" Although some of Louisiana’s claims fall within the settlement, the state did not waive its sovereign immunity. Receipt of the CAFA Notice was insufficient to unequivocally demonstrate that the state was aware that it was a class member and voluntarily chose to have its claims resolved. View "In re: Flonase Antitrust Litigation" on Justia Law

The Ninth Circuit affirmed the district court's order compelling arbitration of putative class action claims against AT&T by customers who alleged that AT&T falsely advertised their mobile service plans as "unlimited" when in fact it intentionally slowed data at certain usage levels. The panel held that there was no state action in this case, rejecting plaintiffs' claim that there was state action whenever a party asserts a direct constitutional challenge to a permissive law under Denver Area Educational Telecommunications Consortium, Inc. v. FCC, 518 U.S. 727 (1996). The panel held that Denver Area did not broadly rule that the government was the relevant state actor whenever there was a direct constitutional challenge to a "permissive" statute, and did not support finding state action here. The panel also held that the Federal Arbitration Act merely gives AT&T the private choice to arbitrate, and did not encourage arbitration such that AT&T's conduct was attributable to the state. View "Roberts v. AT&T Mobility, LLC" on Justia Law

The Supreme Court affirmed the district court’s dismissal of Plaintiffs’ putative class action lawsuit in which they alleged that Salt Lake City unjustly enriched itself by fining them for failing to use a parking meter at a time when there were no longer any parking meters in the City - only pay stations - but the City had not yet prohibited parking without paying at a pay station. Plaintiffs also alleged that the City’s notices violated due process. The district court granted the City’s motion to dismiss. The Supreme Court affirmed, holding (1) the City’s notices were sufficient to apprise Plaintiffs of both their right to challenge their parking tickets and their opportunity for a hearing on that challenge; and (2) because Plaintiffs did not exhaust their legal remedies before seeking to challenge their tickets through an equitable action Plaintiffs failed to state an equitable enrichment claim. View "Bivens v. Salt Lake City" on Justia Law

A plaintiff may rely on the "deterrent effect doctrine" to establish constitutional standing under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., where she lacks firsthand knowledge that an establishment is not in ADA compliance. A plaintiff has constitutional standing where her only motivation for visiting a facility is to test it for ADA compliance. The Ninth Circuit held that, although plaintiffs in this case have standing to maintain their ADA suit, the district court did not abuse its discretion in denying class certification because plaintiffs failed to meet the commonality requirement in Federal Rule of Civil Procedure 23. View "Civil Rights Education and Enforcement Center v. Hospitality Properties Trust" on Justia Law

Plaintiffs, a group of CareFirst customers, filed a putative class action after CareFirst suffered a cyber attack in which its customers' personal information was allegedly stolen. The D.C. Circuit reversed the district court's dismissal of the complaint based on lack of standing. In this case, because the district court dismissed for lack of subject-matter jurisdiction without expressly inviting plaintiffs to amend their complaint or giving some other equally clear signal that it intended the action to continue, the order under review ended the district court action, and was thus final and appealable. On the merits, the court held that plaintiffs have standing where the fact that plaintiffs have reasonably spent money to protect themselves against a substantial risk created the potential for them to be made whole by monetary damages. View "Attias v. CareFirst, Inc." on Justia Law