Justia Class Action Opinion Summaries

This case involved a proposed class action settlement between AOL and plaintiffs where the parties agreed that AOL would make a series of charitable donations. At issue was whether the district court abused its discretion in approving the proposed class action settlement, including a proposed cy pres settlement distribution. The court held that the cy pres distributions here did not comport with the court's cy pres standards. While the donations were made on behalf of a nationwide plaintiff class, they were distributed to geographically isolated and substantively unrelated charities. The court concluded that the district court judge did not have to recuse herself pursuant to 28 U.S.C. 455(a) or (b)(4), 5(iii). The court declined to address the issue of whether the class notice was sufficient. Accordingly, the court reversed in part, affirmed in part, and remanded. View "Nachshin, et al. v. AOL, LLC" on Justia Law

Appellants appealed the district court's denial of certification of their putative class action in Mancini v. Ticketmaster; Stearns v. Ticketmaster, and Johnson v. Ticketmaster. Appellants' actions were directed against a number of entities that were said to have participated in a deceptive internet scheme, which induced numerous individuals to unwittingly sign up for a fee-based rewards program where amounts were charged to their credit cards or directly deducted from their bank accounts. The court held that Rule 23 did not give the district court broad discretion over certification of class actions and the district court erred when it based its exercise of that discretion on what turned out to be an inaccurate reading of the California Unfair Competition Law (UCL), Cal. Bus. & Prof. Code 17200-17210. Therefore, the court reversed the district court's denial of the motions for class certification of the UCL claims in Mancini and affirmed its determination that Mancini and Sanders were not proper representatives. The court affirmed the district court's dismissal of the California's Consumers Legal Remedies Act (CLRA), Cal. Civ. Code 1750-1784, claim in Stearns; affirmed the district court's refusal to certify a class regarding the CLRA injunctive relief claims in Mancini; reversed the district court's dismissal of the Johnson action regarding the CLRA claim; and affirmed its refusal to certify a class regarding the Electronic Fund Transfer Act (EFTA), 15 U.S.C. 1693-1693r, claim in Mancini.

Plaintiffs in this consolidated class action allege copyright infringements arising from defendant publishers' unauthorized electronic reproduction of plaintiff authors' written works. The district court certified a class for settlement purposes and approved a settlement agreement over the objection of ten class members (objectors). In this appeal, objectors challenged the propriety of the settlement's release provision, the certification of the class, and the process by which the district court reached its decisions. Although the court rejected the objectors' arguments regarding the release, the court concluded that the district court abused its discretion in certifying the class and approving the settlement because the named plaintiffs failed to adequately represent the interest of all class members. The court did not reach the procedural challenges, which were moot in light of the court's class certification holding. Therefore, the court vacated the district court's order and remanded for further proceedings.

The Township brought a putative class action on behalf of itself and similarly situated New Jersey municipalities, alleging that defendants, companies who operate hotel booking sites online, owe unpaid hotel occupancy taxes. Defendants calculate the tax owed based on the negotiated rate paid by a defendant (wholesale rate), not the higher rate charged consumers (retail rate). Defendants pay the tax to the hotel, which remits it to the state taxing authority.The district court dismissed on grounds of prudential standing, holding that state officials have the right to enforce the statutory tax scheme. The Third Circuit affirmed. The Township is not the proper plaintiff. Authority to adopt a hotel tax is granted municipalities by N.J. Stat. 40:48F-1, but administration and collection are left to state officials.