Justia Class Action Opinion Summaries

Christopher Meek purchased a universal life insurance policy from Kansas City Life Insurance Company, which combined a standard life insurance policy with a savings account. Meek alleged that Kansas City Life improperly included profits and expenses in the cost of insurance, which was not mentioned in the policy, leading to a lower cash value in his account. Meek filed a federal lawsuit for breach of contract and conversion, and the district court certified a class of about 6,000 Kansans with Meek as the lead plaintiff.The United States District Court for the Western District of Missouri found that Meek's lawsuit was timely for payments going back five years under Kansas’s statute of limitations. The court granted partial summary judgment in favor of Meek on the breach-of-contract claim, interpreting the policy against Kansas City Life. The conversion claim was dismissed. A jury awarded over $5 million in damages, which was reduced to $908,075 due to the statute of limitations. Both parties appealed.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s class certification, finding that common questions of law and fact predominated. The court also upheld the application of Kansas law for both the conversion claim and the statute of limitations. The court agreed with the district court’s interpretation of the insurance policy, concluding that the cost of insurance should not include profits and expenses. The court found that the jury’s damages award was supported by reasonable evidence and did not warrant an increase.The Eighth Circuit affirmed the district court’s judgment, including the class certification, the application of Kansas law, the partial summary judgment in favor of Meek, and the damages award. View "Meek v. Kansas City Life Ins. Company" on Justia Law

Christopher Meek purchased a universal life insurance policy from Kansas City Life Insurance Company, which combined a standard life insurance policy with a savings account. Meek alleged that Kansas City Life improperly included profits and expenses in the cost of insurance, which was not mentioned in the policy, leading to a lower cash value in his account. Meek filed a federal lawsuit for breach of contract and conversion, and the district court certified a class of about 6,000 Kansans with Meek as the lead plaintiff.The United States District Court for the Western District of Missouri found that Meek's lawsuit was timely under Kansas’s five-year statute of limitations for breach-of-contract claims. The court granted partial summary judgment in favor of Meek on the breach-of-contract claim, concluding that the policy's cost-of-insurance provision was ambiguous and should be construed against Kansas City Life. The jury awarded over $5 million in damages, which was reduced to $908,075 under the statute of limitations. Both parties appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that the cost-of-insurance provision in the policy did not include profits and expenses, as these were not listed factors. The court also upheld the class certification, finding that common questions of law and fact predominated over individual issues. Additionally, the court agreed with the district court's application of Kansas law for the conversion claim and the statute of limitations for the breach-of-contract claim. The court found that the jury's damages award was supported by sufficient evidence and did not warrant an increase. View "Meek v. Kansas City Life Ins. Company" on Justia Law

Lawanda Small, a beneficiary and additional insured of her deceased husband's Allianz life insurance policy, filed a class action lawsuit against Allianz Life Insurance Company. She alleged that Allianz violated California Insurance Code sections 10113.71 and 10113.72 by failing to comply with notice procedures required to prevent policies from lapsing due to nonpayment of premiums. Small sought to represent two subclasses: the "Living Insured Subclass" seeking equitable relief to reinstate life insurance coverage, and the "Beneficiary Subclass" seeking damages from death benefits where the insured was deceased.The United States District Court for the Central District of California certified the class, finding that both subclasses satisfied the requirements of Federal Rule of Civil Procedure 23(a) and 23(b). The court granted summary judgment for Small and the class on their breach of contract and declaratory relief claims, ruling that Allianz improperly lapsed the policies by failing to comply with the Statutes. Allianz appealed, arguing that the district court erred in certifying the class and that the summary judgment orders violated the one-way intervention prohibition.The United States Court of Appeals for the Ninth Circuit reversed the district court's order certifying the class and vacated the summary judgment orders. The appellate court held that to recover for alleged violations of the Statutes, plaintiffs must show not only that the insurer violated the notice requirements but also that the violation caused them harm. The court found that individual questions of causation and injury predominated over common questions, making class certification inappropriate. Additionally, the court determined that Small was not an adequate representative with typical questions to represent both subclasses. The case was remanded for further proceedings. View "Small v. Allianz Life Insurance Co. of North America" on Justia Law

Yolanda Bell obtained an automobile insurance policy from Shelter General Insurance Company. In February 2018, her vehicle was damaged, and Shelter determined it was a total loss, paying her $11,787 after deductions. Bell filed a class action suit in February 2022, alleging that Shelter breached its contractual duties by not including taxes and fees required to acquire a replacement vehicle in its payment. Bell argued that the policy did not require her to replace the vehicle before being reimbursed for these costs.The Circuit Court of Jackson County dismissed Bell's petition without prejudice, agreeing with Shelter's argument that the policy only covered taxes and fees if they were actually incurred by purchasing a replacement vehicle. Bell appealed the decision, standing on her original petition rather than amending it.The Supreme Court of Missouri reviewed the case de novo. The court found that Bell's petition adequately pleaded a breach of contract claim by alleging the existence of the insurance policy, her performance under the policy, Shelter's failure to pay the required taxes and fees, and the resulting damages. The court emphasized that the interpretation of the policy's terms was a matter for summary judgment or trial, not for a motion to dismiss. Consequently, the Supreme Court of Missouri reversed the circuit court's judgment and remanded the case for further proceedings. View "Bell vs. Shelter General Insurance Company" on Justia Law

Shymikka Griggs filed a data-breach action against NHS Management, LLC, a consulting firm providing management services for nursing homes and physical-rehabilitation facilities. NHS collects sensitive personal and health information from employees, patients, and vendors. In May 2021, NHS discovered a cyberattack on its network, which lasted 80 days. NHS notified affected individuals, including Griggs, in March 2022. Griggs, a former NHS employee, claimed her personal information was found on the dark web, leading to credit issues, spam communications, and fraudulent activities.Griggs initially filed a class-action complaint in the United States District Court for the Northern District of Alabama but later dismissed it. She then filed a class-action complaint in the Jefferson Circuit Court in June 2023, alleging negligence, negligence per se, breach of contract, invasion of privacy, unjust enrichment, breach of confidence, breach of fiduciary duty, and violation of the Alabama Deceptive Trade Practices Act. NHS moved to dismiss the complaint, arguing lack of standing and failure to state a claim. The Jefferson Circuit Court dismissed Griggs's complaint with prejudice.The Supreme Court of Alabama reviewed the case and affirmed the circuit court's judgment. The court held that Griggs failed to sufficiently plead her claims. Specifically, she did not demonstrate that NHS owed her a duty under Alabama law, failed to establish proximate cause for her negligence per se claim, did not allege intentional conduct for her invasion-of-privacy claim, and did not show that she conferred a benefit on NHS for her unjust-enrichment claim. Additionally, the court found that breach of confidence is not a recognized cause of action in Alabama and that Griggs did not establish a fiduciary relationship between her and NHS. View "Griggs v. NHS Management, LLC" on Justia Law

The case involves a class action lawsuit brought by Jacklin Romeo, Susan S. Rine, and Debra Snyder Miller against Antero Resources Corporation. The plaintiffs, who own oil and gas interests in Harrison County, West Virginia, allege that Antero breached the terms of their leases by failing to pay the full one-eighth royalty specified in the leases. They argue that Antero improperly deducted postproduction costs from the gross sale proceeds of the gas, contrary to West Virginia Supreme Court precedents in Wellman v. Energy Resources, Inc. and Estate of Tawney v. Columbia Natural Resources, L.L.C.The United States District Court for the Northern District of West Virginia, which is handling the case, certified two questions to the Supreme Court of Appeals of West Virginia. The first question asked whether the requirements of Wellman and Estate of Tawney extend only to the "first available market" as opposed to the "point of sale" when the duty to market is implicated. The second question asked whether the marketable product rule extends beyond gas to require a lessee to pay royalties on natural gas liquids (NGLs) and, if so, whether the lessors share in the cost of processing, manufacturing, and transporting the NGLs to sale.The Supreme Court of Appeals of West Virginia answered the first question in the negative, holding that the requirements of Wellman and Estate of Tawney extend to the point of sale, not just to the first available market. The court reaffirmed that the lessee must bear all costs incurred in exploring for, producing, marketing, and transporting the product to the point of sale unless the lease provides otherwise.For the second question, the court held that the marketable product rule extends beyond gas to require a lessee to pay royalties on NGLs. However, the court also held that absent express language in the lease to the contrary, the lessors do not share in the cost of processing, manufacturing, and transporting residue gas and NGLs to the point of sale. View "Jacklin Romeo, Susan S. Rine, and Debra Snyder Miller v. Antero Resources Corporation" on Justia Law

In 2007, Dennis Collins, Suzanne Collins, David Butler, and Lucia Bott purchased long-term care insurance policies from Metropolitan Life Insurance Company (MetLife). They also bought an Inflation Protection Rider, which promised automatic annual benefit increases without corresponding premium hikes, though MetLife reserved the right to adjust premiums on a class basis. In 2015, 2018, and 2019, MetLife informed the plaintiffs of significant premium increases. The plaintiffs filed a class action in 2022, alleging fraud, fraudulent concealment, violations of state consumer protection statutes, and breach of the implied covenant of good faith and fair dealing under Illinois and Missouri law.The United States District Court for the Eastern District of Missouri dismissed the case, ruling that the filed rate doctrine under Missouri and Illinois law barred the plaintiffs' claims. Additionally, the court found that the plaintiffs bringing claims under Missouri law failed to exhaust administrative remedies. The plaintiffs appealed, arguing that the filed rate doctrine did not apply, they were not required to exhaust administrative remedies, and their complaint adequately alleged a breach of the implied covenant.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's dismissal. The appellate court held that the plaintiffs' complaint failed to state a claim upon which relief could be granted. The court found that MetLife's statements about premium expectations were not materially false and that the plaintiffs did not sufficiently allege intentional fraud or fraudulent concealment. The court also concluded that the statutory claims under the Missouri Merchandising Practices Act and the Illinois Consumer Fraud and Deceptive Business Practices Act were barred by regulatory exemptions. Lastly, the court determined that the implied covenant of good faith and fair dealing was not breached, as MetLife's actions were expressly permitted by the policy terms. View "Collins v. Metropolitan Life Insurance Co." 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

Anthony Cordero, a student at Montana State University (MSU) during the Spring 2020 semester, sued MSU for prorated reimbursement of his tuition and fees after the university transitioned to online learning due to the COVID-19 pandemic. Cordero claimed that MSU breached an express contract to provide in-person education and services. He also asserted claims for breach of implied contract, unjust enrichment, due process violation, violation of the takings clause, and inverse condemnation.The First Judicial District Court of Lewis and Clark County dismissed four of Cordero’s six claims, including the implied contract and unjust enrichment claims, under M. R. Civ. P. 12(b)(6). The court granted summary judgment in favor of MSU on the remaining claims, including the express contract claim, and denied Cordero’s motion to certify the case as a class action. The court found that Cordero did not identify a specific, bargained-for promise by MSU to provide in-person education and that he had no compensable property interest in the tuition and fees paid.The Supreme Court of the State of Montana reviewed the case and affirmed the lower court's decisions. The court held that there was an express contract between Cordero and MSU, but it did not include a specific promise to provide in-person education. The court found that MSU had the right to change its regulations and policies, including transitioning to online learning during emergencies. The court also affirmed the dismissal of the implied contract and unjust enrichment claims, noting that an implied contract cannot exist when an express contract is present. The court concluded that MSU did not breach its contractual duties regarding tuition and fees, as it maintained campus facilities and services to the extent possible during the pandemic. View "Cordero v. Montana State University" on Justia Law

Plaintiff, a Bank of America (BOA) accountholder, was charged two separate out-of-network (OON) balance inquiry fees when using a non-BOA ATM. She claimed that only the first fee was permissible under the contract, arguing that a "balance inquiry" should be defined as a customer-initiated request for balance information. BOA contended that it could charge a fee whenever an ATM transmitted a balance inquiry request, regardless of the customer's actions.The United States District Court for the Southern District of California granted summary judgment in favor of BOA on both the breach of contract and breach of the implied covenant of good faith and fair dealing claims. The court also denied class certification, reasoning that individual issues predominated over common ones, particularly concerning the subjective intent of each class member and variations in ATM prompts.The United States Court of Appeals for the Ninth Circuit reversed the district court's summary judgment on the breach of contract claim, agreeing with the plaintiff that a "balance inquiry" should be defined as a customer-initiated transaction. The court found that BOA's interpretation, which allowed fees based on ATM transmittals, was unreasonable and not supported by the contract's language. The court affirmed the summary judgment on the implied covenant of good faith and fair dealing claim, as it was indistinguishable from the breach of contract claim. The court also affirmed the district court's decision that the plaintiff's failure to follow pre-dispute procedures did not bar her claim.The Ninth Circuit vacated the denial of class certification and remanded the case for reconsideration, noting that the court's interpretation of "balance inquiry" alleviated concerns about the need to probe the subjective intent of individual class members. View "Schertzer v. Bank of America, NA" on Justia Law