Justia Class Action Opinion SummariesArticles Posted in Contracts
Anderson v. Magellan Health, Inc.
The Court of Chancery affirmed the judgment of the trial court awarding $75,000 in fees and expenses to Plaintiff's counsel in the underlying stockholder class action instead of the requested award of $1,100,000, holding that the amount requested in this case was unreasonable because the benefits achieved by mooting the lawsuit were insignificant.Plaintiff brought the underlying action challenging a merger agreement under which Centene Corporation agreed to acquire Magellan Health, Inc. Specifically, Plaintiff claimed that, as part of a sale process conducted by Magellan, prospective bidders entered confidentiality agreements that contained provisions that rendered stockholder disclosures materially deficient. Shortly thereafter, Magellan issued supplemental disclosures and waived its rights under three of the four confidentiality agreements. These actions mooted Plaintiff's claims and stipulated to dismissal. Plaintiff's counsel then petitioned the court for the $1,100,000 attorneys' fees and expenses award. The court awarded $75,000 in fees and expenses. The Court of Chancery affirmed and then issued this decision to warn other courts applying Delaware law of policy dangers in regard to mootness fee petitions, holding that there was no error in the award of fees and expenses in this case. View "Anderson v. Magellan Health, Inc." on Justia Law
Webb v. Injured Workers Pharmacy, LLC
The First Circuit affirmed in part and reversed in part the judgment of the district court dismissing this putative action asserting various state law claims in relation to a data breach that allegedly exposed Plaintiffs' personally identifiable information (PII) and that of more than 75,000 other patients of Injured Workers Pharmacy, LLC (IWP), holding that remand was required.Plaintiffs brought a class action complaint against IWP, a home-delivery pharmacy service registered and headquartered in Massachusetts, asserting state law claims for negligence, breach of implied contract, unjust enrichment, invasion of privacy, and breach of fiduciary duty. Plaintiffs sought to certify a class of United States residents whose PII was compromised in the data breach at issue. The district court granted IWP's motion to dismiss for lack of Article III standing. The First Circuit reversed in part, holding (1) the complaint plausibly demonstrated Plaintiffs' standing to seek damages; and (2) Plaintiffs lacked standing to pursue injunctive relief because their desired injunctions would not likely redress their alleged injuries. View "Webb v. Injured Workers Pharmacy, LLC" on Justia Law
Citizens Insurance Company of America v. Wynndalco Enterprises, LLC
After Wynndalco Enterprises, LLC was sued in two putative class actions for violating Illinois’ Biometric Information Privacy Act (“BIPA”), its business liability insurer, Citizens Insurance Company of America, filed an action seeking a declaration that it has no obligation under the terms of the insurance contract to indemnify Wynndalco for the BIPA violations or to supply Wynndalco with a defense. Citizens’ theory is that alleged violations of BIPA are expressly excluded from the policy coverage. Wynndalco counterclaimed, seeking a declaration to the contrary that Citizens is obligated to provide it with defense in both actions. The district court entered judgment on the pleadings for Wynndalco. The Seventh Circuit affirmed. The court explained that the narrowing construction that Citizens proposes to resolve that ambiguity is not supported by the language of the provision and does not resolve the ambiguity. Given what the district court described as the “intractable ambiguity” of the provision, the court held Citizens must defend Wynndalco in the two class actions. This duty extends to the common law claims asserted against Wynndalco in the other litigation, which, as Citizens itself argued, arise out of the same acts or omissions as the BIPA claim asserted in that suit. View "Citizens Insurance Company of America v. Wynndalco Enterprises, LLC" on Justia Law
Andrez Marquez, et al v. Amazon.com, Inc.
At the start of the COVID-19 pandemic, Amazon.com, Inc. (“Amazon”) stopped providing “Rapid Delivery”1 to Amazon Prime (“Prime”) subscribers. Because Prime subscribers were not notified of the suspension and continued to pay full price for their memberships, Plaintiff and others brought a putative class action against Amazon alleging breach of contract, breach of the covenant of good faith and fair dealing, violation of the Washington Consumer Protection Act (“WCPA”), and unjust enrichment. The district court granted Amazon’s motion to dismiss the First Amended Complaint for failure to state a claim with prejudice because it found that Amazon did not have a duty to provide unqualified Rapid Delivery to Prime subscribers. The Eleventh Circuit affirmed. The court first wrote that it is allowed to use its “experience and common sense” to acknowledge the COVID-19 pandemic even though it was not included as a factual allegation in the First Amended Complaint. The court dispensed with this argument because Amazon’s prioritization of essential goods during the COVID-19 pandemic obviously did not harm the public interest. Further, the court explained that Plaintiffs specifically incorporated the terms of their contract with Amazon as part of their unjust enrichment count. So, while Plaintiffs may plead breach of contract and unjust enrichment in the alternative, they have not done so. Instead, Plaintiffs pleaded a contractual relationship as part of their unjust enrichment claim, and that contractual relationship defeats their unjust enrichment claim under Washington law. View "Andrez Marquez, et al v. Amazon.com, Inc." on Justia Law
State ex rel. West Virginia-American Water Co. v. Honorable Webster
In a putative class action involving a water main break the Supreme Court denied a requested writ of prohibition sought by West Virginia-American Water Company (WVAWC) to preclude enforcement of the circuit court's order certifying an "issues" class pursuant to W. Va. R. Civ. P. 23(c)(4), holding that WVAWC failed to demonstrate that the circuit court's class certification was clearly erroneous.The water break in this case and its ensuing repair resulted in water service interruptions that caused outages, inadequate water pressure, and boil water advisories affecting 25,000 WVAWC customers. Respondents filed this putative class complaint on behalf of the putative class asserting breach of contract and other claims. The circuit court certified the "issues" class to determine "the overarching common issues" as to WVAWC's liability, resulting in WVAWC bringing this action. The Supreme Court denied the requested writ of prohibition, holding that WVAWC failed to demonstrate that the circuit court's class certification was clearly erroneous. View "State ex rel. West Virginia-American Water Co. v. Honorable Webster" on Justia Law
Ford Motor Credit Co. v. Miller
The Supreme Court reversed the judgment of the circuit court finding that Ford Motor Credit Company, LLC failed to meet its evidentiary burden to show the existence of an arbitration agreement in this case surrounding a dispute over the unpaid balance on an automobile loan, holding that the circuit court erred.Ford Credit sued Ronald Miller for the alleged balance due on a loan. Miller asserted a class action counterclaim for unlawful debt collection practices, in response to which Ford Credit filed a motion to compel arbitration. The circuit court denied the motion, concluding that Ford Credit failed to provide evidence that an arbitration agreement existed. The Supreme Court reversed and remanded the case, holding that the existence of an arbitration agreement between the parties had been established. View "Ford Motor Credit Co. v. Miller" on Justia Law
Angell v. GEICO Advantage Ins
Plaintiffs sued Defendants GEICO Advantage Insurance Company and its related entities. Each Plaintiff possessed a vehicle that was subject to a private passenger auto insurance policy with a different Defendant (collectively, the “Policies”). Each Plaintiff’s vehicle was involved in an auto collision while insured under one of the Policies. Plaintiffs sought to represent a class of insureds claiming that GEICO failed to fully compensate them for the total loss of their vehicles under their respective insurance policies. The district court held that Plaintiffs had standing to sue on behalf of the proposed class and subsequently granted class certification. GEICO appealed both holdings. The Fifth Circuit affirmed. The court wrote it is clear that each Plaintiff individually satisfies the less stringent class certification approach. Indeed, there is no dispute that each Plaintiff alleges that he or she has suffered some injury; the disagreement between the parties concerns how those injuries relate to those of the class. Further, the court wrote it disagreed with the contention that Plaintiffs have alleged three separate injuries. GEICO’s failure to remit any of the three Purchasing Fees amounts to the same harm—a breach of the Policies. The court also concluded that the strategic value of these claims’ waiver is considerably greater than their inherent worth. It was accordingly within the district court’s discretion to rule that Plaintiffs are adequate class representatives. Moreover, the court wrote that GEICO’s arguments against class certification for this claim largely track its arguments opposing certification of Plaintiffs’ other claims. The district court’s analysis meets the requisite rigor when read in the broader context of its decision. View "Angell v. GEICO Advantage Ins" on Justia Law
Benda v. Prairie Meadows Racetrack & Casino Inc.
The Supreme Court affirmed the judgment of the district court refusing to certify Appellant's case as a class action, holding that, based on the facts and circumstances of this case, the district court did not abuse its broad discretion.Appellant, a horse breeder and owner, brought this putative class action claiming that Prairie Meadows Racetrack and Casino, Inc. breached contracts governing the distribution of winnings among owners and breeders of successful horses. The district court ultimately denied certification. The Supreme Court affirmed, holding that there was no abuse of discretion in the district court's determination that Appellant was not an appropriate class representative and that certification was inappropriate. View "Benda v. Prairie Meadows Racetrack & Casino Inc." on Justia Law
Eddlemon v. Bradley Universityx
In March 2020, Bradley University closed its campus and canceled in-person activities because of the COVID-19 pandemic. It canceled one week of classes as it migrated to remote learning. Bradley resumed classes virtually and offered remote activities and resources. The campus remained closed for the rest of the semester. Bradley never rescheduled the week of canceled classes; the Spring 2020 Semester was 14 weeks instead of the planned 15 weeks of classes listed in Bradley’s Catalog, which stated: “This catalog serves as a contract between a student and Bradley.” Full-time, on-campus students had paid $17,100 in tuition and an $85 activity fee. The University provided pro-rata refunds for room and board to students who were forced to leave on-campus housing but did not refund tuition or activity fees.Eddlemon filed a purported class action, alleging that Bradley breached an implied contract to provide 15 weeks of classes and on-campus activities, and, alternatively that the University’s retention of tuition and activity fees constituted unjust enrichment. The district court certified a “Tuition Class” and an “Activity Fee Class.” The Seventh Circuit vacated. The district court did not conduct the rigorous analysis required by Rule 23 for class certification but repeatedly referred to Eddlemon’s allegations without addressing his proffered evidence or examining how he would prove his allegations with common evidence. View "Eddlemon v. Bradley Universityx" on Justia Law
Lowell Lundstrom, Jr. v. Watts Guerra LLP
Plaintiff filed suit against Homolka, Homolka P.A., Watts Guerra, and Watts, alleging he is owed (1) $10,000 per month as leasing payments from October 2015, the first month he stopped receiving payments, until the September 2017 settlement; (2) a promised $50,000 truck reimbursement; and (3) a $3.4 million bonus. The jury returned a unanimous verdict for Plaintiff, finding that Homolka breached the oral contract, acting as an agent of Homolka P.A. and Watts Guerra. The jury awarded $175,000 in compensatory damages with no prejudgment interest. The district court denied Watts Guerra’s renewed motion for judgment as a matter of law and Plaintiff’s motion for a new trial. Watts Guerra and Plaintiff cross-appealed these rulings. The Eighth Circuit affirmed. The court held that it agreed with the district court that the jury reasonably found Watts Guerra liable on an ostensible agency theory for Homolka’s breaches of the contract underlying the jury’s award of $175,000 in compensatory damages. The court reasoned that in considering these issues, “we start with the assumption jurors fulfilled their obligation to decide the case correctly,” and “we defer second to the trial court, which has a far better sense of what the jury likely was thinking and also whether there is any injustice in allowing the verdict to stand.” Applying these deferential standards, the court wrote that it has no difficulty concluding the district court did not abuse its discretion in denying Plaintiff’s motion for a new trial. The jury verdict awarding $175,000 compensatory damages was neither inadequate nor the product of an inappropriate compromise. View "Lowell Lundstrom, Jr. v. Watts Guerra LLP" on Justia Law