Justia Class Action Opinion Summaries

Spokeo operates a “people search engine,” which searches a wide spectrum of databases to gather and provide personal information about individuals to various users, including prospective employers. After Robins discovered that his Spokeo-generated profile contained inaccurate information, he filed a class-action complaint alleging that the company willfully failed to comply with the Fair Credit Reporting Act of 1970, 15 U.S.C. 1681e(b). The district court dismissed. The Ninth Circuit reversed, reasoning that Robins’ “personal interests in the handling of his credit information are individualized.” The Supreme Court vacated. A plaintiff invoking federal jurisdiction bears the burden of establishing the “irreducible constitutional minimum” of standing by demonstrating an injury in fact, fairly traceable to the defendant’s challenged conduct, likely to be redressed by a favorable judicial decision. A plaintiff must show that he suffered “an invasion of a legally protected interest” that is “concrete and particularized” and “actual or imminent, not conjectural or hypothetical.” The Ninth Circuit’ focused on particularization: the requirement that an injury “affect the plaintiff in a personal and individual way,” but an injury in fact must be both concrete and particularized. Concreteness requires an injury to actually exist; a plaintiff does not automatically satisfy the injury-in-fact requirement whenever a statute grants a right and purports to authorize a suit to vindicate it. The violation of a statutory procedural right granted can be sufficient in some circumstances to constitute injury in fact, so that a plaintiff need not allege additional harm beyond the one identified by Congress. The Court did not rule on the correctness of the Ninth Circuit’s ultimate conclusion, but stated that Robins cannot satisfy Article III by alleging a bare procedural violation. View "Spokeo, Inc. v. Robins" on Justia Law

After EyeCare Specialties, P.C. of Lincoln terminated the employment of Cindy Marshall, Marshall sued, alleging that EyeCare discriminated against her because of her skin condition, tremors, and perceived disability related to her past prescription drug abuse. The district court granted summary judgment in favor of EyeCare. The Supreme Court reversed, holding (1) a genuine issue of material fact existed concerning whether EyeCare discriminated against Marshall because of her skin condition and tremors, both of which EyeCare perceived to substantially limit Marshall’s ability to work; and (2) Marshall failed to present evidence that EyeCare discriminated against her for having a perceived drug addiction that substantially limited one or more major life activities. View "Marshall v. EyeCare Specialties, P.C." on Justia Law

Insured filed a complaint alleging that Insured had breached a title insurance policy. Insured also alleged that Insurer had acted in bad faith and requested an award of attorney’s fees and costs pursuant to Va. Code Ann. 38.2-209. Insured demanded a jury trial “on all counts so triable.” Insurer sought to have the trial judge, rather than the jury, consider the issues of bad faith and attorney’s fees. The jury was permitted to award attorney’s fees. The jury found in favor of Insured and awarded $442,000 in attorneys’ fees and costs. The trial court judge vacated the jury’s award of attorney’s fees and costs, ruling that section 38.2-209(A) requires a judge, not a jury, to determine whether an insurer committed a bad faith breach of an insurance contract warranting an award of attorney’s fees. Reconsidering the evidence de novo, the judge then concluded that the evidence was insufficient to prove that Insurer had acted in bad faith. The Supreme Court affirmed, holding (1) a judge, not a jury, must determine whether an insurer has acted in bad faith under the policy; and (2) section 38.2.209(A) does not implicate the right to a jury trial under Va. Const. art. I, 11. View "REVI, LLC v. Chicago Title Ins. Co." on Justia Law

Defendant was charged with violating Mass. Gen. Laws ch. 56, 42, which criminalizes certain false statements about political candidates or questions submitted to voters, after her political action committee published brochures criticizing a candidate for public office. Defendant filed a petition pursuant to Mass. Gen. Laws ch. 211, 3 seeking relief from the criminal complaint on the ground that section 42 is unconstitutional. The Supreme Judicial Court granted the requested relief, holding (1) section 42 is inconsistent with the fundamental right of free speech enshrined in article 16 of the Massachusetts Declaration of Rights and is, therefore, invalid; and (2) accordingly, the criminal complaint charging Defendant with violating section 42 must be dismissed. View "Commonwealth v. Lucas" on Justia Law

In these consolidated cases, BP appealed three settlement awards, related to the 2010 Deepwater Horizon oil spill, that it paid to nonprofits through its Court-Supervised Settlement Program. On appeal, BP argued that the Claims Administrator improperly interpreted the Settlement Agreement. The awards were based on the Claims Administrator’s determination that nonprofits may count donations and grants as “revenue” under the terms of the Agreement (the Nonprofit-Revenue Interpretation). As a preliminary matter, the court concluded that it has jurisdiction over this appeal under the collateral order doctrine and that BP's appeals were timely. On the merits, the court concluded that BP failed to show that the Nonprofit-Revenue Interpretation violates the plain language of the Agreement. The court held that the Nonprofit-Revenue Interpretation does not alter the class definition in violation of Rule 23 or Article III. Finally, the court concluded that there was no abuse of discretion in the district court's denial of review of the individual awards. Accordingly, the court affirmed the judgment. View "In Re: Deepwater Horizon" on Justia Law

This appeal stemmed from five putative class actions filed against Wells Fargo and its predecessor, Wachovia Bank. At issue was whether Wells Fargo's waiver of its right to compel arbitration of the named plaintiffs' claims should be extended to preclude Wells Fargo from compelling arbitration of the unnamed putative class members' claims. The court concluded that because a class including the unnamed putative class members had not been certified, Article III's jurisdictional limitations precluded the district court from entertaining Wells Fargo's conditional motions to dismiss those members' claims as subject to arbitration; contrary to the position they take in this appeal, the named plaintiffs lack Article III standing to seek the court's affirmance of the district court's provision holding that if a class is certified, Wells Fargo will be estopped to assert its contractual rights to arbitration; and, therefore, the court vacated and remanded for further proceedings. View "Spears-Haymond v. Wells Fargo Bank" on Justia Law

After a jury trial, Defendant was convicted of aggravated murder, aggravated robbery, and having weapons under disability. Prior to trial, Defendant filed a suggestion of incompetence to stand trial and a plea of not guilty by reason of insanity. A psychologist conducted a court-ordered evaluation on the issues of Defendant’s competency and sanity. Defendant later withdrew the defenses. On appeal, Defendant argued that the trial court violated his Fifth Amendment privilege against self-incrimination when it allowed the psychologist to testify during trial. The court of appeals reversed Defendant’s convictions for aggravated murder and aggravated robbery, concluding that Ohio Rev. Code 2945.371(J) prohibits the use of statements made by a defendant in a psychiatric evaluation against the defendant on the issue of guilt in a criminal action. The Supreme Court affirmed, holding (1) when a defendant asserts a mental-capacity defense, resulting in the court ordering a psychiatric evaluation, but then the defendant wholly abandons the defense, a psychologist’s testimony regarding the defendant’s feigning of mental illness during the court-ordered evaluation is inadmissible in the state’s case-in-chief pursuant to section 2945.371(J); and (2) the trial court’s admission of the psychologist’s testimony in this case was not harmless error. View "State v. Harris" on Justia Law

The Special Management Unit housing unit within the Lewisburg U.S. Penitentiary houses inmates identified as having violent tendencies or having a history of gang involvement while incarcerated. Inmates assigned to the SMU are confined to their cells for 23 hours a day, but can spend the remaining hour in a recreation cage. When first assigned to the SMU, inmates are interviewed by prison officials to ensure that inmates who may be hostile to each other are not housed in the same cell. Shelton, a USP inmate, filed a purported class action, alleging that the defendants have engaged in a pattern, practice, or policy of improperly placing inmates who are known to be hostile to each other in the same cell. He also claims that the defendants fail to intervene when the predictable inmate-on-inmate violence erupts, and that defendants improperly restrain inmates who refuse cell assignments with inmates who are known to be hostile to them. The district court denied Shelton’s motion for class certification and granted defendants’ motion for summary judgment. The Third Circuit affirmed dismissal of a Federal Tort Claims Act claim, but vacated the denial of class certification and summary judgment as to an Eighth Amendment claim. View "Shelton v. Bledsoe" on Justia Law

Plaintiff filed a class action suit against Old Republic, a company that sells home warranty plans, alleging that Old Republic arbitrarily denied claims made by him and a putative class of similarly situated policyholders of Old Republic plans, or otherwise cheated him and this class out of benefits owed under their policies. On appeal, plaintiff challenged the district court's orders denying his motion for class certification, denying his motion for leave to amend his complaint, and granting Old Republic's motion for partial summary judgment. The court did not reach the merits of the district court's order because the appeal is moot. The parties settled all of plaintiff's claims and plaintiff expressly released all of his claims against Old Republic. Applying Narouz v. Charter Commc'sn, the court concluded that the appeal is moot because plaintiff has no financial interest or other personal interest whatsoever in class certification. View "Campion v. Old Republic Protection Co." on Justia Law

Non-Settling Defendants seek to overturn a partial final judgment approving the settlement of certain putative class actions. The settled claims were brought by Investor Plaintiffs who were individual and institutional investors in so-called Bernard Madoff feeder funds managed by the Fairfield Greenwich Group (Settling Defendants). The Non-Settling Defendants challenged a provision in the settlement agreement that provides that investors who filed claims under the settlement submit to the district court's jurisdiction for the sole purpose of participating in the settlement and not for any other purpose. The court joined its sister circuits in holding that a settlement which does not prevent the later assertion of a non-settling party's claims, does not cause the non-settling party "formal" legal prejudice. Therefore, the court concluded that the Non-Settling Defendants did not have standing to object to the settlement. The court declined to address the remaining issues on appeal and dismissed for lack of standing.View "Pricewaterhousecoopers, LLP, et al. v. Bhatia, et al." on Justia Law