Justia Class Action Opinion Summaries

A group of Union Pacific Railroad Company employees filed a class action lawsuit against the company, alleging that its fitness-for-duty program violated the Americans with Disabilities Act (ADA). Todd DeGeer, believing he was part of this class, filed an Equal Employment Opportunity Commission (EEOC) charge and an individual lawsuit after the class was decertified. DeGeer argued that his claims were tolled under the American Pipe & Construction Co. v. Utah doctrine. The district court dismissed his claims as untimely, finding that DeGeer was not a member of the narrowly defined class.The United States District Court for the District of Nebraska initially certified a class that included Union Pacific employees subjected to fitness-for-duty evaluations due to a reportable health event. DeGeer was on a list of employees provided by Union Pacific and submitted a declaration supporting the plaintiffs' certification motion. However, the class definition was later narrowed, and the district court certified the class under this new definition. The Eighth Circuit Court of Appeals later reversed the class certification, leading DeGeer to file his individual claims.The United States Court of Appeals for the Eighth Circuit reviewed the case and reversed the district court's decision. The Eighth Circuit held that DeGeer was entitled to American Pipe tolling because the revised class definition did not unambiguously exclude him. The court emphasized that ambiguities in class definitions should be resolved in favor of applying tolling. Consequently, DeGeer's claims were tolled during the pendency of the class action, making his individual lawsuit timely. The case was remanded for further proceedings. View "DeGeer v. Union Pacific Railroad Co." on Justia Law

Four former Tesla employees, Sharonda Taylor, Shaka Green, Tatianna Smith, and Zenobia Milligan, requested personnel records from Tesla under the California Labor Code. These individuals are also part of a class action lawsuit, Vaughn v. Tesla, which alleges racial discrimination and harassment at Tesla's Fremont plant. Despite the requests, Tesla did not provide the requested records, citing a stay in the Vaughn case due to an ongoing appeal. The plaintiffs then filed a Private Attorneys General Act (PAGA) action against Tesla for failing to comply with the Labor Code.The Superior Court of California, County of Alameda, denied Tesla's anti-SLAPP motion, which argued that the PAGA claims arose from protected petitioning activity related to the Vaughn case. The court found that the plaintiffs' requests for personnel records were independent of the Vaughn litigation and were merely an exercise of their statutory rights under the Labor Code.The California Court of Appeal, First Appellate District, Division Four, affirmed the lower court's decision. The appellate court held that Tesla's refusal to provide the requested records did not constitute protected activity under the anti-SLAPP statute. The court distinguished this case from Crossroads Investors, L.P. v. Federal National Mortgage Assn., noting that the plaintiffs' PAGA claims did not rely on any "written or oral statement or writing" by Tesla. The court also found that Tesla's conduct did not meet the criteria for protection under the anti-SLAPP statute's "catchall" provision, as it did not contribute to any public issue or debate. Consequently, the court affirmed the denial of Tesla's anti-SLAPP motion. View "Taylor v. Tesla, Inc." on Justia Law

Robert Anthony Zaragoza, a former brakeman and train conductor for Union Pacific Railroad Company, was terminated in 2015 after testing positive for cocaine but was later reinstated. In 2016, he failed a color vision test and subsequent retests, leading to his removal from service and denial of recertification as a conductor. Zaragoza contested these results, submitting medical reports attesting to his adequate color vision, but was not reinstated.Zaragoza argued that his claims were tolled from 2016 to 2020 due to his inclusion in a class action against Union Pacific, Harris v. Union Pacific Railroad Co. The district court for the Western District of Texas dismissed his claims as untimely, finding that the tolling ended with the class certification order in February 2019, and the statute of limitations expired before Zaragoza filed his EEOC charge in March 2020.The United States Court of Appeals for the Fifth Circuit reviewed the case and determined that Zaragoza was included in both the putative and certified class definitions in the Harris class action. The court held that the statute of limitations for Zaragoza's claims was tolled during the pendency of the Harris class action, from the time his claims accrued until the Eighth Circuit decertified the class in March 2020. Consequently, Zaragoza's claims were timely when he filed his EEOC charge.The Fifth Circuit reversed the district court's dismissal of Zaragoza's disability discrimination claims and remanded the case for further proceedings, declining to address Union Pacific's alternate grounds for summary judgment. View "Zaragoza v. Union Pacific Railroad" on Justia Law

Four former Tesla employees, Sharonda Taylor, Shaka Green, Tatianna Smith, and Zenobia Milligan, requested personnel records from Tesla through their counsel, Bryan Schwarz Law (BSL), under the California Labor Code. These individuals are also part of a class action lawsuit, Vaughn v. Tesla, which alleges racial discrimination and harassment at Tesla's Fremont factory. During the Vaughn litigation, BSL sent Tesla privacy waivers and statutory personnel records requests on behalf of numerous employees, including the plaintiffs. Tesla did not respond to these requests, citing a stay in the Vaughn proceedings due to an appeal.The Superior Court of California, County of Alameda, denied Tesla's anti-SLAPP motion, which sought to strike the plaintiffs' PAGA complaint. The court found that Tesla failed to show that the plaintiffs' claims arose from protected petitioning activity under the anti-SLAPP statute. The court ruled that the plaintiffs were exercising their statutory rights to inspect and copy personnel records, independent of the Vaughn litigation.The California Court of Appeal, First Appellate District, Division Four, affirmed the lower court's decision. The appellate court held that Tesla's refusal to provide the requested personnel records did not constitute protected petitioning activity under the anti-SLAPP statute. The court distinguished this case from Crossroads Investors, L.P. v. Federal National Mortgage Assn., noting that the plaintiffs' claims did not involve any "written or oral statement or writing" by Tesla. The court also found that Tesla's conduct did not further any public issue or contribute to public debate, as required under the anti-SLAPP statute's catchall provision. Consequently, the appellate court affirmed the denial of Tesla's anti-SLAPP motion. View "Taylor v. Tesla, Inc." on Justia Law

A trial court found that Yakima HMA LLC wrongfully withheld nearly $1.5 million in wages from its nurses over five years. In 2015, the Washington State Nurses Association (WSNA) filed a claim on behalf of 28 nurses, including Daniel Campeau. The trial court ruled in favor of WSNA, but years later, the Supreme Court of Washington reversed this decision, stating that WSNA lacked associational standing. Before the mandate was issued, Campeau filed a class action suit to recover the unpaid wages.The trial court agreed with Campeau, allowing the case to proceed under the doctrine of equitable tolling, reasoning that Campeau had diligently pursued his claims through the WSNA action and reasonably relied on the union to protect his rights. Yakima HMA appealed, and the Court of Appeals reversed the trial court's decision, concluding that American Pipe tolling was not applicable in Washington and that equitable tolling was not warranted without evidence of bad faith or misconduct by Yakima HMA.The Supreme Court of Washington reviewed the case de novo. The court held that equitable tolling could be appropriate even without bad faith by the defendant when associational standing fails, and a member promptly files a follow-on class action. The court found that equitable tolling was consistent with the purposes of the underlying labor laws and statutes of limitations, and it would prevent an unjust windfall to Yakima HMA. Therefore, the court reversed the Court of Appeals and remanded the case to the trial court for further proceedings. View "Campeau v. Yakima HMA, LLC" on Justia Law

This case is a class action involving commercial truck drivers who claimed they were not paid properly by Werner Enterprises, Inc., and Drivers Management, LLC. The drivers alleged that they were not adequately compensated for off-duty time spent on short rest breaks and time spent resting in their trucks’ sleeper-berths. The case has been appealed multiple times, with the court previously vacating a jury verdict in favor of the drivers because the district court improperly allowed the drivers to submit an expert report after the deadline. On remand, the district court entered judgment in favor of the defendants. The drivers appealed again, and the court vacated the judgment and remanded the case back to the district court to conduct an analysis regarding whether the expert report should be excluded as a discovery sanction and whether the district court should appoint an independent expert.On remand, the district court concluded that exclusion of the drivers’ expert report was the appropriate sanction for its late disclosure and that appointment of an independent expert was not appropriate. It then entered judgment in favor of the defendants. The drivers appealed this decision, asserting that the district court erred in its analysis. The defendants cross-appealed, asserting that the drivers’ notice of appeal was untimely, requiring dismissal of the appeal.The United States Court of Appeals for the Eighth Circuit rejected the defendants’ contention on cross-appeal and affirmed the judgment of the district court. The court found that the district court did not abuse its discretion in excluding the expert report and denying the drivers’ motion for a new trial. The court also found that the district court did not err in declining to appoint an expert and in entering judgment in favor of the defendants. View "Petrone v. Werner Enterprises, Inc." on Justia Law

The plaintiff, Mary Rodgers-Rouzier, worked as a bartender on steamboats operated by American Queen. She alleged that she and her coworkers were wrongly denied overtime wages. Rodgers-Rouzier filed a suit as a collective action, and over one hundred of her coworkers joined her proposed collective action. Meanwhile, American Queen moved to dismiss the case, arguing that Rodgers-Rouzier had agreed to arbitration. The district court denied the motion, but American Queen moved again to dismiss based on the arbitration agreement, this time invoking Indiana state law. The district court granted this motion, over Rodgers-Rouzier’s objections.The district court had previously denied American Queen's motion to dismiss the case for improper venue because Rodgers-Rouzier had agreed to arbitration. However, American Queen then moved again to dismiss based on the arbitration agreement, this time invoking Indiana state law. The district court granted this motion, over Rodgers-Rouzier’s objections that American Queen had waived its argument and the court lacked authority to apply Indiana law in this context. The court further determined that all the workers who had filed consent forms were not parties to the action.The United States Court of Appeals for the Seventh Circuit reversed the district court's decision. The court concluded that although American Queen’s arguments were not waived and the court had authority to enforce the arbitration agreement under Indiana law, Indiana law would hold American Queen to its bargain that its arbitration agreement was governed by the Federal Arbitration Act (FAA). Therefore, Rodgers-Rouzier’s case may continue in federal court. The court did not decide whether it may do so as a collective action and left that question for further litigation. View "Rodgers-Rouzier v. American Queen Steamboat Operating Company, LLC" on Justia Law

Joseph Work, a former employee of Intertek, filed a collective action against the company for unpaid overtime, liquidated damages, attorneys’ fees, and relief for the collective class. Intertek objected to the judicial forum and requested arbitration. The dispute centered on whether the agreed-upon Arbitration Agreement provided for individual or class arbitration. Work sought class arbitration, while Intertek sought individual arbitration. Intertek filed a Motion to Compel Individual Arbitration, arguing that the Arbitration Agreement did not contain an express delegation clause and was silent on class arbitration.The United States District Court for the Southern District of Texas ruled that the issue of class arbitrability was delegated to the arbitrator. The court held that the Arbitration Agreement incorporated certain JAMS Rules by reference, which delegate questions of arbitrability to the arbitrator, including the question of class arbitrability. The district court granted Work’s motion to dismiss and denied Intertek’s motion to compel individual arbitration.On appeal to the United States Court of Appeals for the Fifth Circuit, Intertek argued that consent to class arbitration was absent and that the language in the Arbitration Agreement was not clear. The court rejected both arguments, affirming the district court's decision. The court held that the Arbitration Agreement was not ambiguous and that it clearly incorporated the JAMS Rules by reference. The court concluded that the language in the Arbitration Agreement was "clear and unmistakable" in its incorporation of the JAMS Rules, which provide that the arbitrator decides the question of arbitrability. View "Work v. Intertek" on Justia Law

The case involves plaintiffs Christopher Maia and Sean Howarth, who were employed as laborers for defendant IEW Construction Group. The company required them to perform “pre-shift” and “post-shift” work, for which they were not paid. Both Maia and Howarth were laid off in November 2021. In April 2022, they filed a class action complaint alleging that IEW violated the Wage Payment Law (WPL) and the Wage and Hour Law (WHL).The trial judge held that Chapter 212, which amended the WPL and WHL, does not apply retroactively and thus dismissed plaintiffs’ claims for conduct that arose prior to Chapter 212’s effective date of August 6, 2019. The Appellate Division reversed this decision.The Supreme Court of New Jersey granted leave to appeal. The court held that Chapter 212 is to be applied prospectively to conduct that occurred on or after August 6, 2019, not retroactively to conduct that occurred before that date. The trial judge properly dismissed the portions of the complaint relying on Chapter 212 but arising from conduct prior to its effective date. The court reversed the Appellate Division’s judgment, reinstated the trial judge’s order partially dismissing plaintiffs’ complaint, and remanded for further proceedings. View "Maia v. IEW Construction Group" on Justia Law

The plaintiff, Ryan S., filed a class action lawsuit against UnitedHealth Group, Inc. and its subsidiaries (collectively, “UnitedHealthcare”) under the Employee Retirement Income Security Act of 1974 (“ERISA”). He alleged that UnitedHealthcare applies a more stringent review process to benefits claims for outpatient, out-of-network mental health and substance use disorder (“MH/SUD”) treatment than to otherwise comparable medical/surgical treatment. Ryan S. asserted that by doing so, UnitedHealthcare violated the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 (“Parity Act”), breached its fiduciary duty, and violated the terms of his plan.The district court granted UnitedHealthcare’s motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) based primarily on its conclusions that Ryan S. failed to allege that his claims had been “categorically” denied and insufficiently identified analogous medical/surgical claims that he had personally submitted and UnitedHealthcare had processed more favorably.The United States Court of Appeals for the Ninth Circuit reversed in part and affirmed in part the district court’s judgment. The panel concluded that Ryan S. adequately stated a claim for a violation of the Parity Act. The panel explained that an ERISA plan can violate the Parity Act in different ways, including by applying, as Ryan S. alleged here, a more stringent internal process to MH/SUD claims than to medical/surgical claims. The panel also concluded that Ryan S. alleged a breach of fiduciary duty. However, as Ryan S. failed to identify any specific plan terms that the alleged practices would violate, the panel affirmed the dismissal of his claims based on a violation of the terms of his plan. The case was remanded for further proceedings. View "Ryan S. v. UnitedHealth Group, Inc." on Justia Law