Justia Class Action Opinion Summaries

Plaintiffs William Pace and Robert Walters leased apartments at Hamilton Cove, a complex in Weehawken, New Jersey, based on advertisements claiming 24/7 security. After moving in, they discovered that the security was not as advertised. They filed a complaint in March 2022, alleging common law fraud and violations of the Consumer Fraud Act (CFA), seeking to certify a class of similarly affected tenants. The leases included a class action waiver, which defendants argued should prevent the class action. Plaintiffs contended the leases were unconscionable contracts of adhesion.The trial court denied defendants' motion to dismiss, finding the complaint sufficiently pled fraud. The Appellate Division affirmed, holding that class action waivers in contracts without mandatory arbitration provisions are unenforceable as a matter of public policy. The court distinguished this case from AT&T Mobility LLC v. Concepcion, which upheld class action waivers in arbitration agreements under the Federal Arbitration Act (FAA). The Appellate Division emphasized New Jersey's public policy favoring class actions for consumer protection.The Supreme Court of New Jersey reviewed the case and reversed the Appellate Division's decision. The Court held that class action waivers in consumer contracts are not inherently contrary to public policy and can be enforceable unless found to be unconscionable or invalid under general contract principles. The Court found that the class action waiver in the lease agreements was clear and unambiguous, and the leases were not unconscionable. Therefore, the class action waiver was enforceable, and plaintiffs must pursue their claims individually. The case was remanded for further proceedings consistent with this opinion. View "Pace v. Hamilton Cove" on Justia Law

This case involves a class action lawsuit against Logan Health Medical Center ("Logan Health") following a significant data breach of its information technology systems. The breach, which occurred on November 22, 2021, exposed highly sensitive personal identifying information and protected health information of over 200,000 current and former patients and others affiliated with Logan Health. Patricia Tafelski, on behalf of herself and all others similarly situated, filed a complaint against Logan Health. After a series of negotiations, the parties agreed to a settlement of $4.3 million for a common fund. The District Court granted preliminary approval of the proposed settlement on December 6, 2022.The District Court of the Eighth Judicial District, in and for the County of Cascade, granted final approval of the Settlement Agreement, awarded Class Counsel attorney fees, and denied the Objectors’ motion for discovery. The Objectors, Mark Johnson and Tammi Fisher, appealed the order, arguing that the attorney fees of 33.33% of the settlement fund were unreasonable and that their motion for discovery was wrongly denied.The Supreme Court of the State of Montana affirmed the lower court's decision. The court found that the District Court did not abuse its discretion in awarding Class Counsel attorney fees. The court also found that the District Court did not abuse its discretion in denying the Objectors’ motion for discovery. The court noted that the District Court had made adequate findings on each of the factors for determining the reasonableness of attorney fees and that those findings were supported by the record. The court also noted that the District Court had conscientiously considered the nature of the litigation and the interests of the class in denying the Objectors’ motion for discovery. View "Tafelski v. Johnson" on Justia Law

The case revolves around Robert Nightingale, who owed money to National Grid. The company hired two debt collectors who called Nightingale more than twice over several seven-day periods throughout 2017 and 2018. Nightingale sued National Grid and the debt collectors under the Massachusetts Consumer Protection Act, alleging that the calls invaded his privacy and caused him emotional distress. He also sought to certify a class of Massachusetts residents who had experienced similar invasions of privacy due to excessive calls from the defendants.The case was moved to federal district court, which declined to certify the class, stating that it did not meet the predominance requirement of Federal Rule of Civil Procedure 23(b)(3). The district court also granted summary judgment to the defendants, finding that Nightingale had not demonstrated a cognizable injury under the Massachusetts Consumer Protection Act.The United States Court of Appeals for the First Circuit disagreed with the district court's rulings. The appellate court held that Nightingale had alleged cognizable injuries, vacated the district court's grant of summary judgment, and also vacated the denial of class certification. The case was remanded for further proceedings consistent with the appellate court's opinion. The court found that Nightingale's receipt of unwanted calls constituted a cognizable invasion of privacy, and that his emotional distress was a cognizable injury under the Massachusetts Consumer Protection Act. The court also found that the district court had applied an incorrect legal rule in its class certification analysis. View "Nightingale v. National Grid USA Service Company Inc." on Justia Law

The case involves a consumer, Yoram Kahn, who alleges that Walmart Inc., the nation's largest retailer, engages in deceptive and unfair pricing practices. Kahn claims that there are small discrepancies between the prices advertised on Walmart's shelves and the prices actually charged at the cash register. These discrepancies, he alleges, add up to hundreds of millions of dollars each year. Kahn argues that these practices violate the Illinois Consumer Fraud and Deceptive Business Practices Act, the Illinois Uniform Deceptive Trade Practices Act, and other states' consumer protection statutes. He also brings a claim for unjust enrichment and seeks to sue on behalf of a class of similarly situated consumers.The district court dismissed the case on the pleadings and denied leave to amend the complaint. The court reasoned that providing a customer with a receipt after payment stating the actual price charged is sufficient to dispel any potential deception or unfairness caused by an inaccurate shelf price. The court also held that Kahn failed to allege that Walmart intended for him to rely on the inaccurate shelf pricing.The United States Court of Appeals for the Seventh Circuit reversed the district court's decision. The appellate court held that the complaint states some viable claims. The court rejected the theory that providing a receipt after payment is sufficient to dispel any potential deception or unfairness caused by an inaccurate shelf price. The court also found that Kahn had adequately alleged a deceptive or unfair practice and the required intent. The court remanded the case for further proceedings. View "Kahn v. Walmart Inc." on Justia Law

The case involves Gillian and Samuel Davidson, who filed a class action lawsuit against Sprout Foods, Inc., alleging that the labels on Sprout's baby food pouches violated California's Sherman Law, which incorporates all federal food labeling standards. The Davidsons claimed that Sprout's labels, which stated the amount of nutrients the pouches contained, were misleading and harmful to consumers.The district court dismissed the Davidsons' claims. It ruled that the Sherman Law claim was preempted by federal law, which only allows the federal government to enforce food labeling standards. The court also dismissed the Davidsons' fraud-based claims, stating that they failed to specifically allege why Sprout's products were harmful.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part. The court held that federal law did not preempt private enforcement of the Sherman Law's labeling requirements. The court reasoned that the federal food labeling statute permits states to enact labeling standards identical to the federal standards, which California has done through the Sherman Law. Therefore, the district court should not have dismissed the Sherman Law claims. However, the court affirmed the dismissal of the Davidsons' fraud-based claims, agreeing with the lower court that the Davidsons failed to meet the heightened pleading requirements for fraud. The court also reversed the dismissal of an unjust enrichment claim, which survived due to the reversal on the Sherman Law claim. View "Davidson v. Sprout Foods, Inc." on Justia Law

The case revolves around a data privacy dispute involving Pebbles Martin and LCMC Health Holdings and Louisiana Children’s Medical Center (collectively, “LCMC”). Martin filed a class action suit alleging that LCMC violated Louisiana law by embedding tracking pixels onto its website that shared her private health information with third-party websites. The question before the court was not to determine the merits of Martin’s claims, but instead to determine which forum—state or federal—is proper to hear this dispute. LCMC argued that the suit should proceed in federal court because it acted under the direction of a federal officer when it allegedly violated Louisiana law. Martin, however, argued that the suit should remain in state court because LCMC fails to show a basis for federal jurisdiction.LCMC had removed the case to federal court, invoking the federal officer removal statute as the basis for jurisdiction. Martin moved to remand to state court, and the district court granted Martin’s motion, holding that LCMC did not act under the direction of a federal officer when it disclosed private health information to third-party websites. LCMC appealed the remand order.The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court concluded that LCMC did not act under the direction of a federal officer when it embedded tracking pixels onto its website. The court noted that a hospital does not act under the direction of the federal government when it maintains an online patient portal that utilizes tracking pixels. Therefore, the federal officer removal statute does not provide jurisdiction for this case to be heard in federal court. The court affirmed the district court’s order remanding this case to state court. View "Martin v. LCMC Health Holdings" on Justia Law

The case involves a group of plaintiffs who filed a class-action lawsuit against KIND, LLC, a snack food company. The plaintiffs alleged that the phrase "All Natural" on the labels of KIND's products was deceptive and misleading. They sought damages on behalf of themselves and three classes, based on common law fraud, as well as consumer protection and false advertising laws in New York, California, and Florida.The District Court for the Southern District of New York granted KIND's motion for summary judgment, concluding that the plaintiffs had failed to establish how a reasonable consumer would understand the term "All Natural." The court held that this was fatal to the plaintiffs' claims because without showing how a reasonable consumer understood the term, the plaintiffs could not explain how or why they were materially deceived. The court also granted KIND's motion to preclude two of the plaintiffs' expert opinions from the summary judgment record and to decertify the classes.On appeal, the United States Court of Appeals for the Second Circuit affirmed the District Court's decision. The appellate court held that the District Court did not abuse its discretion in precluding the opinions of the plaintiffs' experts. The court also held that because the plaintiffs failed to present admissible evidence of what a reasonable consumer would expect of KIND products labeled "All Natural," the District Court did not err in concluding that there was no triable issue of fact as to whether reasonable consumers would be misled by the "All Natural" labeling. The court further held that the plaintiffs' arguments regarding class decertification were moot because the District Court's grant of summary judgment was affirmed. View "In re: Kind LLC "Healthy and All Natural" Litigation" on Justia Law

A group of individuals, including a minor, filed a class action lawsuit against Warner Bros. Entertainment, Inc. for alleged misrepresentations related to the mobile application Game of Thrones: Conquest (GOTC). The plaintiffs claimed that Warner Bros. engaged in false and misleading advertising within the game. In response, Warner Bros. moved to compel arbitration of all claims based on the GOTC Terms of Service, which users agree to by tapping a “Play” button located on the app’s sign-in screen. The district court denied Warner Bros.' motion, finding that the notice of the Terms of Service was insufficiently conspicuous to bind users to them.The case was appealed to the United States Court of Appeals for the Ninth Circuit. The lower court had found that Warner Bros. failed to provide reasonably conspicuous notice of its Terms of Service, thus denying the motion to compel arbitration. The district court focused on whether the context of the transaction put the plaintiffs on notice that they were agreeing to the Terms of Service, concluding that the app did not involve a continuing relationship that would require some terms and conditions.The Ninth Circuit Court of Appeals reversed the district court's decision. The appellate court held that the district court erred in finding that Warner Bros. failed to provide reasonably conspicuous notice. The court found that the context of the transaction and the placement of the notice were both sufficient to provide reasonably conspicuous notice. The court also rejected the plaintiffs' argument that the arbitration agreement was unconscionable due to its ban on public injunctive relief. The court concluded that the unenforceability of the waiver of one’s right to seek public injunctive relief did not make either this provision or the arbitration agreement unconscionable or otherwise unenforceable. The case was remanded for further proceedings. View "KEEBAUGH V. WARNER BROS. ENTERTAINMENT INC." on Justia Law

The case involves a consumer class action against Nutramax Laboratories, Inc. and Nutramax Laboratories Veterinary Sciences, Inc. (collectively, “Nutramax”), alleging that Nutramax violated the California Consumers Legal Remedies Act by falsely marketing its pet health product, Cosequin, as promoting healthy joints in dogs. The plaintiffs, Justin Lytle and Christine Musthaler, claimed that Cosequin provided no such health benefits. The district court certified a class of California purchasers of certain Cosequin products who were exposed to the allegedly misleading statements.The district court had certified the class based on the proposed damages model of Plaintiffs’ expert, Dr. Jean-Pierre Dubé, to find that common questions predominated as to injury. Nutramax appealed, arguing that the district court erred in relying on an unexecuted damages model to certify the class and that the element of reliance was not susceptible to common proof.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The appellate court held that there was no general requirement that an expert actually apply to the proposed class an otherwise reliable damages model in order to demonstrate that damages are susceptible to common proof at the class certification stage. The court also rejected Nutramax’s contention that the district court incorrectly concluded that the element of reliance was susceptible to common proof. The district court properly found that classwide reliance may be established under the CLRA through proof that a misrepresentation is material. View "LYTLE V. NUTRAMAX LABORATORIES, INC." on Justia Law

Yasmin Varela filed a class action lawsuit against State Farm Mutual Automobile Insurance Company (State Farm) after a car accident. Varela's insurance policy with State Farm entitled her to the "actual cash value" of her totaled car. However, she alleged that State Farm improperly adjusted the value of her car based on a "typical negotiation" deduction, which was not defined or mentioned in the policy. Varela claimed this deduction was arbitrary, did not reflect market realities, and was not authorized by Minnesota law. She sued State Farm for breach of contract, breach of the covenant of good faith and fair dealing, unjust enrichment, and violation of the Minnesota Consumer Fraud Act (MCFA).State Farm moved to dismiss the complaint, arguing that Varela's claims were subject to mandatory, binding arbitration under the Minnesota No-Fault Automobile Insurance Act (No-Fault Act). The district court granted State Farm's motion in part, agreeing that Varela's claims for breach of contract, breach of the covenant of good faith and fair dealing, and unjust enrichment fell within the No-Fault Act's mandatory arbitration provision. However, the court found that Varela's MCFA claim did not seek the type of relief addressed by the No-Fault Act and was neither time-barred nor improperly pleaded, and thus denied State Farm's motion to dismiss this claim.State Farm appealed, arguing that Varela's MCFA claim was subject to mandatory arbitration and should have been dismissed. However, the United States Court of Appeals for the Eighth Circuit dismissed the appeal for lack of jurisdiction. The court found that State Farm did not invoke the Federal Arbitration Act (FAA) in its motion to dismiss and did not file a motion to compel arbitration. The court concluded that the district court's order turned entirely on a question of state law, and the policy contained no arbitration provision for the district court to "compel." Therefore, State Farm failed to establish the court's jurisdiction over the interlocutory appeal. View "Varela v. State Farm Mutual Automobile Insurance Co." on Justia Law