Justia Class Action Opinion Summaries

Three health care workers sued their hospital employer in this putative class and private attorney general enforcement action for alleged Labor Code violations and related claims. In this appeal, the workers argued that a hospital policy illegally let health care employees waive their second meal periods on shifts longer than 12 hours. A statute requires two meal periods for shifts longer than 12 hours. But an order of the Industrial Welfare Commission (IWC) authorized employees in the health care industry to waive one of those two required meal periods on shifts longer than 8. The principal issue this case presented for the Court of Appeal's review centered on the validity of the IWC order. After review, the Court concluded the IWC order was partially invalid to the extent it authorized second meal break waivers on shifts longer than 12 hours. However, with one exception, the retroactive application of the Court's conclusion had to be litigated on remand. The Court also determined the court incorrectly granted summary judgment and denied class certification. View "Gerard v. Orange Coast Mem. Medical Center" on Justia Law

Maurice McGinnis sought a loan through federal farm credit programs and alleges that he was denied access to such programs by the Department because of his race. This appeal concerns McGinnis' participation in a claims process established by a class action settlement agreement to resolve his and other farmers' discrimination claims. The court concluded that Paragraph 13 of the Consent Decree empowers the District Court to correct an error by the facilitator in transmitting a claim to the wrong track. If it is true that McGinnis selected Track B and the facilitator nevertheless sent his claim package to the adjudicator, the district court did no more than enforce the parties' agreement. The court affirmed the district court's conclusion that it could review the facilitator's claim processing and vacate the adjudicator's determination. The court concluded that McGinnis' request to change his claim to Track B was sufficiently close in time to his submission of the claim package, and the language of the Consent Decree defining what constitutes a "completed claim package" is sufficiently ambiguous, to justify the district court in granting his petition. Accordingly, the court affirmed the judgment of the district court. View "Pigford v. Vilsack" on Justia Law

Sanitary and Improvement District No. 1, Butler County, Nebraska (SID #1) filed two class action lawsuits in Cass County, Nebraska, alleging that various county treasurers unlawfully deducted an incorrect percentage of assessments of municipal improvements collected on behalf of SID #1 and other sanitary and improvement districts. The county treasurers filed motions to dismiss for failure to state a claim. The district court granted those motions, concluding that the sanitary and improvement districts are not municipal corporations and therefore do not create municipal improvements. SID #1 appealed. The Supreme Court consolidated the appeals and reversed, holding that SID #1 stated a cause of action because a sanitary and improvement district can levy municipal taxes and make municipal improvements. Remanded. View "Sanitary & Improvement Dist. No. 1 v. Adamy" on Justia Law

Plaintiffs Brett Woods and Kathleen Valdes were state employees and representatives of a class of New Mexico state and local government employees who alleged they paid for insurance coverage through payroll deductions and premiums pursuant to a policy issued by Standard Insurance Company (Standard), but did not receive the coverage for which they paid and, in some cases, were denied coverage entirely. Plaintiffs filed suit in New Mexico state court against three defendants: Standard, an Oregon company that agreed to provide the subject insurance coverage; the Risk Management Division of the New Mexico General Services Department (the Division), the state agency that contracted with Standard and was responsible for administering benefits under the policy; and Standard employee Martha Quintana, who Plaintiffs allege was responsible for managing the Division’s account with Standard and for providing account management and customer service to the Division and state employees. Plaintiffs' ninety-one-paragraph complaint, stated causes of action against Standard and the Division for breach of contract and unjust enrichment; against Standard for breach of fiduciary duty, breach of the implied duty of good faith and fair dealing, and Unfair Practices Act violations; and against Standard and Ms. Quintana for breach of the New Mexico Trade Practices and Fraud Act. The issue this appeal presented for the Tenth Circuit's review centered on whether remand to the state court pursuant to the Class Action Fairness Act (CAFA) was required under either of two CAFA provisions: the state action provision, which excludes from federal jurisdiction cases in which the primary defendants are states; or the local controversy exception, which requires federal courts to decline jurisdiction where, among other things, there is a local defendant whose alleged conduct forms a significant basis for the claims asserted by plaintiffs and from whom plaintiffs seek significant relief. The Court concluded that neither provision provided a basis for remand, and therefore reversed the decision of the magistrate judge remanding the case to state court. But because the Tenth Circuit could not determine whether Defendants have established the amount in controversy required to confer federal jurisdiction, the case was remanded to the district court for the resolution of that issue. View "Woods v. Standard Insurance Co." on Justia Law

The State appealed a three-judge district court order directing California to remedy two ongoing violations of the Cruel and Unusual Punishments Clause, a guarantee binding on the States by the Due Process Clause of the Fourteenth Amendment, by reducing the prison system population where the violations were the subject of two class actions involving a class of prisoners with serious mental disorders and a class of prisoners with serious medical conditions. At issue was whether the remedial order issued by the three-judge court was consistent with requirements and procedures set forth in a congressional statute, the Prison Litigation Reform Act of 1995 ("PLRA"), 18 U.S.C. 3626. The Court held that the court-mandated population limit was necessary to remedy the violation of prisoners' constitutional rights and was authorized by the PLRA.View "Brown, et al. v. Plata, et al." on Justia Law

Plaintiffs filed a class action challenging the constitutionality of Arizona's Proposition 100. Proposition 100 commands that Arizona state courts could not set bail for serious felony offenses as prescribed by the legislature if the person charged has entered or remained in the United States illegally and if the proof was evident or the presumption great as to the charge. After reviewing the record, the court affirmed the district court's grant of summary judgment and partial dismissal, concluding that plaintiffs have not raised triable issues of fact as to whether Proposition 100 and its implementing procedures violated the substantive and procedural due process guarantees of the United State's Constitution's Fourteenth Amendment, the Excessive Bail Clause of the Eighth Amendment, and the Sixth Amendment right to counsel, nor whether the Proposition 100 laws were preempted by federal immigration law. The court concluded that the Arizona Legislature and Arizona voters passed the Proposition 100 laws to further the state's legitimate and compelling interest in seeing that those accused of serious state-law crimes were brought to trial. View "Lopez-Valenzuela v. County of Maricopa" on Justia Law

Plaintiffs receive subsidies from Michigan’s Child Development and Care Program for providing home childcare services for low-income families. Following creation of the Home Based Child Care Council, a union was established and authorized to bargain on their behalf, based on submission of 22,180 valid provider-signed authorization cards out of a possible 40,532 eligible providers. The union and the Council entered into a collective bargaining agreement and the state began deducting union dues and fees from the subsidy payments. Plaintiffs sought to file a class-action lawsuit for the return of the money, collected allegedly in violation of their First Amendment rights. The district court denied certification of plaintiffs’ proposed class (all home childcare providers in Michigan) based on conflict of interest: some members voted for union representation and others voted against representation. Plaintiffs attempted to cure by proposing a subclass of only providers who did not participate in any election related to union representation. The district court rejected the proposal, finding that it could not assume that all members of the subclass opposed representation and that, even if all members of the proposed subclass did oppose representation, their reasons for opposition were different enough to create conflict within the class. The Sixth Circuit affirmed. View "Schlaud v. Snyder" on Justia Law

This case arose when plaintiffs filed a class action suit in state court against the Levee District and Flood Protection Agency. Plaintiffs then initiated a second state court suit against the Levee District and the Agency. Subsequently, plaintiffs filed an amended petition, joining the Corps as a defendant, seeking declaratory judgment that defendants did not possess a servitude over their property. The Corps then removed the case to federal district court, the district court granted in part and denied in part the Corps' motion to dismiss, and the United States petitioned for permission to appeal. At issue on appeal was whether plaintiffs' action against the Corps fell within the scope of the Quiet Title Act (QTA), 28 U.S.C. 2409a, so as to waive the United States' immunity to suit and authorize federal subject matter jurisdiction. Because the title dispute here concerned ownership of the purported servitude - a title dispute between plaintiffs and a third party - and because it was plausible to read the QTA as only authorizing suit when the underlying title dispute was between plaintiff and the United States, the court reversed the judgment of the district court and remanded for further proceedings. View "Lonatro, et al v. United States" on Justia Law

The District of Columbia appealed from the structural injunction entered by the district court in this class action challenging the policies and practices of the District's "Child Find" system under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. The court vacated the order certifying the class, and consequently, the orders finding liability and ordering relief to that class. The court remanded the case to the district court for reconsideration of whether a class, classes, or subclasses may be certified, and if so, thereafter to redetermine liability and appropriate relief. View "DL, et al v. DC, et al" on Justia Law

Tennessee participates in Medicaid through “TennCare,” Tenn. Code 71-5-102. The Medicaid Act requires that TennCare administer an Early and Periodic Screening, Diagnosis, and Treatment program for all enrollees under age 21, 42 U.S.C. 1396a(a)(43), 1396d(r) and must provide outreach to educate its enrollees about these services. In 1998 plaintiffs filed a putative class action under 42 U.S.C. 1983, alleging that TennCare had failed to fulfill these obligations. The district court entered a consent decree that explained in detail the requirements that TennCare had to meet to “achieve and maintain compliance” with the Medicaid Act, based on the assumption that the Act created rights enforceable under section 1983. Eight years later, the Sixth Circuit held that one part of the Medicaid Act was unenforceable under section 1983. Following a remand, the district court vacated paragraphs of the decree that were based on parts of the Act that are not privately enforceable. After a thorough review of TennCare’s efforts, the court then vacated the entire decree, finding that TennCare had fulfilled the terms of the decree’s sunset clause by reaching a screening percentage greater than 80% and by achieving current, substantial compliance with the rest of the decree. The Sixth Circuit affirmed. View "John B. v.Emkes" on Justia Law