Justia Class Action Opinion Summaries

A group of Google Chrome users who chose not to sync their browsers with their Google accounts alleged that Google collected their personal data without consent. They believed that, based on Google's Chrome Privacy Notice, their data would not be collected if they did not enable sync. The users filed a class action lawsuit against Google, claiming violations of various state and federal laws.The United States District Court for the Northern District of California granted summary judgment in favor of Google. The court found that the data collection was "browser-agnostic," meaning it occurred regardless of the browser used. It concluded that Google's general privacy policies, which the users had consented to, governed the data collection. The court held that a reasonable person would understand from these policies that Google collected data when users interacted with Google services or third-party sites using Google services.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision. The appellate court held that the district court should have determined whether a reasonable user would understand Google's various privacy disclosures as consenting to the data collection. The court found that the district court erred by focusing on the technical distinction of "browser agnosticism" rather than the reasonable person standard. The appellate court noted that Google's Chrome Privacy Notice could lead a reasonable user to believe that their data would not be collected without enabling sync. The case was remanded to the district court for further proceedings to determine whether the users consented to Google's data collection practices. View "CALHOUN V. GOOGLE LLC" on Justia Law

A consumer of a glucosamine-based dietary supplement filed a putative class action lawsuit against the supplement’s manufacturer and retailer under New York law. The plaintiff alleged that the supplement was mislabeled because it contained a different formulation of glucosamine than what was displayed on the front of the label and disclosed as the main ingredient on the side. Specifically, the plaintiff claimed that the product contained blended glucosamine rather than single-crystal glucosamine, which she believed to be more effective for alleviating joint pain.The United States District Court for the Eastern District of New York granted summary judgment for the defendants on federal preemption grounds. The court concluded that the plaintiff’s state law mislabeling claims were preempted by the Food, Drug, and Cosmetic Act (FDCA), which establishes national standards for the labeling of dietary supplements. The district court found that the FDCA’s comprehensive regulatory scheme and its broad preemption clauses foreclosed the plaintiff’s state law claims.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that the plaintiff’s state law mislabeling claims were expressly preempted by the FDCA. The court reasoned that the FDCA preempts any state law that imposes labeling requirements not identical to those set forth in the FDCA and its regulations. The court found that the product’s labeling complied with the FDCA’s requirements, as the dietary ingredient “glucosamine sulfate potassium chloride” was identified using methods endorsed by the FDA. Therefore, the plaintiff’s claims were preempted, and the judgment of the district court was affirmed. View "Jackson-Mau v. Walgreen Co." on Justia Law

The plaintiffs, a group of consumers, filed a class action lawsuit against Amazon.com, Inc., alleging that the company violated Washington's Consumer Protection Act (CPA) by charging grossly inflated prices for essential goods during the COVID-19 pandemic. The plaintiffs claimed that Amazon's price increases, which they defined as 15% or more on any consumer good or food item after a declared emergency, were unfair. They also alleged negligence and unjust enrichment.The United States District Court for the Western District of Washington reviewed the case and Amazon moved to dismiss the complaint, arguing that price gouging is not an unfair trade practice under the CPA. The District Court then certified two questions to the Washington Supreme Court: whether the CPA's prohibition on "unfair" acts or practices includes price gouging as alleged, and if so, whether the court or jury determines what percentage increase in price is "unfair."The Washington Supreme Court held that price gouging, as alleged in the plaintiffs' complaint, may be considered an unfair act or practice under the CPA. The court applied the substantial injury test from federal law, which requires that the act causes substantial injury to consumers, is not reasonably avoidable by consumers, and is not outweighed by countervailing benefits. The court found that the plaintiffs adequately alleged substantial injury, lack of reasonable alternatives, and no countervailing benefits.However, the court declined to establish a rigid 15% price increase threshold as a predicate for a price gouging claim, stating that such economic policy decisions are best left to the legislature. Finally, the court determined that whether an act is unfair is generally a mixed question of law and fact for the jury to resolve, unless the facts are undisputed, in which case it is a question of law for the court. View "Greenberg v. Amazon.com, Inc." on Justia Law

Jonathan Michel, a sophomore at Yale University during the Spring 2020 semester, filed a putative class action against Yale after the university transitioned to online-only classes due to the COVID-19 pandemic. Michel sought tuition refunds, claiming promissory estoppel and unjust enrichment under Connecticut law, arguing that Yale's refusal to refund tuition was inequitable since the online education provided was of lower value than the in-person education promised.The United States District Court for the District of Connecticut granted Yale's motion for summary judgment, concluding that Michel did not present evidence of financial detriment caused by the transition to online classes, a necessary element for both promissory estoppel and unjust enrichment claims. The court dismissed Michel's suit on January 31, 2023.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that Michel's quasi-contract claims were barred by a "Temporary Suspension Provision" in Yale's Undergraduate Regulations. This provision, which acted as a force majeure clause, allowed Yale to transition to online-only classes during the pandemic without issuing tuition refunds. The court concluded that Michel and Yale had a contractual relationship governed by this provision, which precluded Michel's quasi-contract claims. Therefore, Yale was entitled to summary judgment. View "Michel v. Yale University" on Justia Law

The case involves a consumer class action against Premier Nutrition Corporation, which marketed Joint Juice, a dietary supplement drink, as effective for relieving joint pain. Mary Beth Montera, representing a class of New York consumers, alleged that Premier's advertising was deceptive and violated New York General Business Law (GBL) §§ 349 and 350. These laws require proof that the defendant engaged in consumer-oriented conduct that was materially misleading and caused injury to the plaintiff.The United States District Court for the Northern District of California certified the class and the case proceeded to trial. Montera presented evidence, including studies showing that Joint Juice's key ingredients, glucosamine and chondroitin, were ineffective for joint health. Premier countered with industry-funded studies supporting the product's efficacy. The jury found Premier's statements deceptive and awarded statutory damages based on the number of units sold in New York during the class period. Premier's post-trial motions to decertify the class and for judgment as a matter of law were denied.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the district court's rulings on class certification, liability under GBL §§ 349 and 350, and the initial calculation of statutory damages. The court rejected Premier's arguments that its statements were not materially misleading and that Montera's injury was not cognizable under New York law. The court also upheld the jury's finding that the class members' injuries were caused by Premier's misrepresentations.However, the Ninth Circuit vacated the district court's award of prejudgment interest, ruling that statutory damages under GBL §§ 349 and 350 are not compensatory and thus do not warrant prejudgment interest. The court also remanded the case for the district court to reconsider the statutory damages award in light of the factors identified in Wakefield v. ViSalus, Inc., which addresses the substantive due process limits on aggregate statutory damages. The court affirmed in part, reversed in part, and vacated and remanded in part. View "MONTERA V. PREMIER NUTRITION CORPORATION" on Justia Law

Cybercriminals hacked into T-Mobile's computer systems, stealing personal information of approximately 76.6 million customers. Several customers filed class action lawsuits against T-Mobile, which were centralized in the U.S. District Court for the Western District of Missouri. The parties reached a settlement, with T-Mobile agreeing to create a $350 million fund for affected customers and to spend an additional $150 million on data security improvements. Class counsel requested $78.75 million in attorneys' fees, which two class members, Cassie Hampe and Connie Pentz, objected to as excessive.The district court struck Hampe's and Pentz's objections and overruled them on the merits. The court found Hampe's objection to be in bad faith, influenced by her attorneys' history as serial objectors, and struck it under Federal Rule of Civil Procedure 12(f). Pentz's objection was struck as a discovery sanction after she refused to cooperate with class counsel's discovery efforts. Both objectors appealed the district court's decisions.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court abused its discretion in striking Hampe's objection, as Rule 12(f) does not apply to objections and there was no evidence of bad faith in this case. The court also found that the district court erred in awarding attorneys' fees, determining that the fee award was unreasonable given the relatively short duration and limited discovery of the case. The court affirmed the decision to strike Pentz's objection but reversed the decision to strike Hampe's objection and the award of attorneys' fees, remanding for further proceedings. View "Daruwalla v. Hampe" on Justia Law

J.M., an 11-year-old student, filed a class action lawsuit through his guardian ad litem against Illuminate Education, Inc., an education consulting business. J.M. alleged that Illuminate obtained his personal and medical information from his school to assist in evaluating his educational progress. Illuminate promised to keep this information confidential but negligently maintained its database, leading to a data breach where a hacker accessed the information. Illuminate delayed notifying J.M. and other victims about the breach for five months, during which J.M. began receiving unsolicited mail and phone calls.The trial court sustained Illuminate's demurrer, concluding that Illuminate did not fall within the scope of the Confidentiality of Medical Information Act (CMIA) or the Customer Records Act (CRA) and that J.M. failed to state a cause of action. J.M. filed a proposed second amended complaint with additional facts and a motion for reconsideration. The trial court reviewed the amended pleadings but maintained that J.M. had not stated a cause of action and could not amend to do so, thus sustaining the demurrer without leave to amend and entering judgment for Illuminate.The California Court of Appeal, Second Appellate District, reviewed the case and concluded that Illuminate falls within the scope of the CMIA and CRA. The court found that J.M. stated sufficient facts to support causes of action under both statutes. The court held that the trial court abused its discretion by sustaining the demurrer without leave to amend. The judgment of dismissal was reversed, and the case was remanded to the trial court, allowing J.M. to file an amended complaint with additional facts. View "J.M. v. Illuminate Education, Inc." on Justia Law

The case involves a putative class action brought by the plaintiff against Kimberly Clark Corp., alleging that the labeling of the defendant's baby wipes was misleading under California's false advertising laws. The plaintiff claimed that the terms "plant-based wipes" and "natural care®" on the front label, along with nature-themed imagery, suggested that the wipes contained only natural ingredients without chemical modifications. However, the wipes contained synthetic ingredients.The United States District Court for the Central District of California separated the product labels into two categories: those with an asterisk and a qualifying statement ("Asterisked Products") and those without ("Unasterisked Products"). The district court dismissed the plaintiff's claims, concluding that both categories were not misleading as a matter of law. The court reasoned that the asterisk and qualifying statement on the Asterisked Products clarified that the wipes were not entirely plant-based, and the back label's disclaimer about synthetic ingredients dispelled any potential misrepresentation for both categories.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court's dismissal of the plaintiff's claims regarding the Unasterisked Products, holding that the front label could plausibly mislead a reasonable consumer to believe the wipes contained only natural ingredients, precluding reliance on the back label at the pleadings stage. However, the court affirmed the dismissal of claims regarding the Asterisked Products, finding that the asterisk and qualifying statement, along with the back label, made it impossible for the plaintiff to prove that a reasonable consumer would be deceived. The court also rejected the defendant's argument that the complaint failed to meet the particularity requirements of Rule 9(b). The case was remanded for further proceedings consistent with the court's opinion. View "WHITESIDE V. KIMBERLY CLARK CORP." on Justia Law

Plaintiff Mark Coziahr filed a class action against Otay Water District, alleging that Otay's tiered water rates for single-family residential customers violated Section 6(b)(3) of Proposition 218, which mandates that property-related fees not exceed the proportional cost of the service attributable to the parcel. The trial court certified the class and found that Otay failed to meet its burden of demonstrating compliance with Section 6(b)(3). In the remedy phase, the court awarded an estimated refund of approximately $18 million, with monthly increases until Otay imposed compliant rates. Otay appealed the liability decision and damages, while Coziahr appealed only as to damages.The Superior Court of San Diego County found that Otay's tiered rates were based on non-cost objectives like conservation and did not correlate with the actual cost of providing water service. The court determined that Otay's reliance on peaking factors and adherence to industry standards were insufficient to justify the tiered rates. The court also found that Otay discriminated against single-family residential customers by charging them more for water than other customer classes without a cogent reason. The court rejected Otay's peaking factor analysis and Mumm's independent analysis as flawed and unsupported by the record.The California Court of Appeal, Fourth Appellate District, Division One, affirmed the trial court's liability determination, holding that Otay did not establish its tiered rates complied with Section 6(b)(3). The court found that Otay's evidence did not withstand independent review and that the trial court properly applied the principles from Capistrano and Palmdale. However, the appellate court reversed the refund amount, finding the trial court's calculations unreasonable due to reliance on projected data and a proxy from another case. The matter was remanded for a new trial on the refund amount, including monthly increases and prejudgment interest. The judgment was otherwise affirmed. View "Coziahr v. Otay Wat. Dist." on Justia Law

In September 2021, cybercriminals targeted a chain of pawnshops, a payday lender, and a prepaid-card company, exposing customers' personal information. The companies informed customers of the breach weeks later, leading to three nationwide class-action lawsuits in the District of Minnesota. The companies moved to dismiss the cases, arguing lack of standing and failure to state a claim, but did not mention arbitration. They continued to engage in litigation activities, including briefing issues, preparing a discovery plan, and requesting a pretrial conference. There is a dispute about whether the companies mentioned arbitration during the pretrial conference, but no formal motion to compel arbitration was filed until months later.The United States District Court for the District of Minnesota found that the companies had waived their right to arbitration by substantially engaging in litigation. The court noted that the companies had no credible explanation for their delay in filing the motion to compel arbitration, despite allegedly deciding to do so during the pretrial conference.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The appellate court applied a two-part test to determine waiver of the right to arbitration, focusing on whether the party knew of the right and acted inconsistently with it. The court concluded that the companies had knowledge of their right to arbitration and acted inconsistently by engaging in extensive litigation activities. The companies' actions, including participating in a motion-to-dismiss hearing and scheduling mediation, were deemed to have substantially invoked the litigation machinery, thus waiving their right to arbitration. The court emphasized that the companies' delay and litigation conduct were inconsistent with promptly seeking arbitration. View "Thomas v. Pawn America Minnesota, LLC" on Justia Law