Justia Class Action Opinion Summaries

Three named plaintiffs in a class action suit to enforce the Fair Labor Standards Act, 29 U.S.C. 216(b) and parallel state laws appealed the district court’s decertification of the classes. Proceeding as individual lawsuits by the three plaintiffs, the case settled, reserving plaintiffs’ right to appeal the decertification. The Seventh Circuit denied a motion to dismiss for lack of jurisdiction. If appeals such as this were held to be precluded on standing grounds, there would be no judicial economies, since if the named plaintiffs settle after denial of class certification and then exit the scene another member of the class can step forward and take the quitters’ place. View "Espenscheid v. DirectSat USA, LLC" on Justia Law

Plaintiffs David McCorkle and William Pender appealed a district court order dismissing two of their class action claims against Bank of America Corporation for alleged violations of certain provisions of the Employment Retirement Income Security Act of 1974 (ERISA). Their claims centered on the Bank's use of a normal retirement age (NRA) that allegedly violated ERISA in calculating lump sum distributions and further ran afoul of ERISA's prohibition of "backloading" the calculation of benefit accrual. Upon review, the Fourth Circuit agreed with the district court's conclusion that Plaintiffs failed to state a claim upon which relief could be granted, and it affirmed the district court's judgment to dismiss those claims. View "Pender v. Bank of America Corp." on Justia Law

Appellant, a former pilot for Vision Airlines, sued Vision on behalf of a Class of other pilots and flight crew employees to recover hazard pay, which Appellant and the Class alleged Vision had accepted on their behalf and never paid to them. After nearly two years of discovery disputes between Vision and the Class, the district court sanctioned Vision by striking its answer, entered default judgment against Vision, and held a jury trial to determine damages. On appeal, the Ninth Circuit Court rejected Vision's arguments that (1) the district court abused its discretion by striking Vision's answer, (2) the claims in the complaint were legally insufficient to support the default judgment, and (3) the district court abused its discretion by certifying the Class. The Court then reversed the order dismissing the Class's claim for punitive damages, holding that the district court erred in dismissing the Class's claim for punitive damages. View "Hester v. Vision Airlines, Inc." on Justia Law

Plaintiffs are current and former drivers for FedEx delivery service who allege that they were employees rather than independent contractors under the laws of the states in which they worked and under federal law. The district court used the Craig. case, which was based on ERISA and Kansas law, as its “lead” case; certified a nationwide class seeking relief under ERISA and certified statewide classes under FRCP 23(b)(3). The Kansas class has 479 members. They allege that they were improperly classified as independent contractors rather than employees under the Kansas Wage Payment Act, Kan. Stat. 44-313, and that as employees, they are entitled to repayment of costs and expenses they paid during their time as FedEx employees. They also seek payment of overtime wages. The district court granted FedEx summary judgment in Craig and other cases; 21 cases are on appeal. The Seventh Circuit stayed proceedings and certified questions to the Kansas Supreme Court: Given the undisputed facts, are the plaintiff drivers employees of FedEx as a matter of law under the KWPA? Drivers can acquire more than one service area from FedEx. Is the answer different for plaintiff drivers who have more than one service area? View "Craig v. FedEx Ground Package Sys., Inc." on Justia Law

Petitioner Leandre Layton, on behalf of himself and the similarly-situated members of his conditionally-certified class (collectively, "Drivers"), appealed the district court's grant of summary judgment in favor of DHL Express, Inc. ("DHL") on his claims under the Fair Labor Standards Act ("FLSA"). DHL contracted with Sky Land Express, Inc. to manage local parcel deliveries. Petitioner worked on DHL routes for Sky Land. Petitioner filed his collective action for unpaid overtime, naming DHL, Sky Land and Gary Littlefield (owner and president of Sky Land) as his joint employers and defendants to the suit. DHL moved for summary judgment on the ground that it was not the drivers' employer. The district court granted DHL's motion: "DHL did everything it could possibly do to relate to Sky Land only as an "independent contractor[."] The contract with Sky Land allowed DHL to exercise only the minimal supervision necessary to monitor compliance with the contract. The undisputed facts lead to the conclusion that if plaintiffs were employed by anybody, they were employed by Sky Land, the entity that they ostentatiously dismissed as a defendant, for reasons this court can only guess at. DHL was not an employer, much less a joint employer." After a thorough examination of the realities of the economic relationship between Drivers and DHL, the Eleventh Circuit affirmed on the grounds that DHL was not a joint employer of the Drivers. View "Layton v. DHL Express (USA), Inc." on Justia Law

Plaintiffs, on behalf of thousands of retired county employees participating in county-sponsored health care plans, filed suit against the county challenging changes it made to the structure of two health benefits. Plaintiffs appealed the district court's order granting a motion for judgment on the pleadings filed by the county. The court reversed and remanded for further proceedings and with the answer provided by the California Supreme Court to the certified question in the Retired Employees Association of Orange County, Inc.(REAOC) litigation. The court took judicial notice of the documents; reversed the district court's dismissal of plaintiffs' subsidy claims and remanded so that the district court could reassess those claims in light of the California Supreme Court's opinion, and coordinate those claims with the REAOC litigation; the court reversed the district court's dismissal of plaintiffs' grant claims because the court found that plaintiffs should be given an opportunity to amend their complaint to set out specifically the terms of those memoranda of understanding (MOUs) on which their claim predicated; and the court reversed the district court's dismissal of plaintiffs' Fair Employment and Housing Act (FEHA), California Government Code 12940 et seq., claim because the court found that Mr. McConnell's timely filed administrative complaint was sufficient to establish exhaustion of the administrative remedies for all class members. View "Harris, et al. v. County of Orange" on Justia Law

Plaintiffs claimed that the fiduciaries of their retirement plan violated the Employment Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., in ways that damaged their efforts to stockpile savings for their winter years. The court held that because plaintiffs have not pleaded facts establishing that defendants abused their discretion by following the Plan's directions, they have not stated a valid claim for breach of the duty of prudence. The court also held that plaintiffs have failed to state a viable breach of loyalty claim. Accordingly, the court affirmed the district court's dismissal of plaintiffs' third and last amended complaint. View "Lanfear, et al. v. Home Depot, Inc., et al." on Justia Law

Appellant, as counsel for a group of 64 retired city firefighters and their families, appealed the district court's approval of a class-action settlement agreement between the city and a certified class of active and retired firefighters, police officers, civilian employees, and their unions. The court held that, given the nature of the case and the potential conflict at issue, the district court did not abuse its discretion in certifying the class or by ensuring fair and adequate representation for the entire class by means other than appointing separate counsel for each subclass. The district court's conclusion that the settlement agreement was a fair, reasonable, and adequate settlement for all of the class members was well within its discretion. Finally, the court rejected appellant's argument that the district court abused its discretion under Rule 23(d) by failing to hold a special hearing on the ability of class counsel to represent the subclass. Accordingly, the court affirmed the judgment. View "Professional Firefighters Assoc., et al. v. Zalewski" on Justia Law

Named plaintiffs sought to represent potential classes of hospital employees, some covered by collective bargaining agreements and others not, claiming that they were deprived of compensation for work performed during meal breaks, before and after shifts, and during training sessions. One case asserted only state law tort and regulatory claims; the other raised claims under the Fair Labor Standards Act, 29 U.S.C. 206-207, and the Employee Retirement Income Security Act, 29 U.S.C.1059(a)(1), 1104(a)(1). The district court dismissed. The First Circuit affirmed in part. The state law claims were properly removed to federal court and were preempted because many were dependent on the terms of a collective bargaining agreement. The federal law claims, dismissed for failure to identify specific employers, were remanded to permit amendment. View "Cavallaro v. UMass Mem'l Health Care,Inc." on Justia Law

This case stemmed from the DLSE's investigation into whether Brinker was complying with its obligations to provide rest and meal breaks to its employees, maintain proper records, and pay premium wages in the event required breaks were not provided. The court considered on appeal issues of significance to class actions generally and to meal and rest break class actions in particular. The court concluded that the trial courts were not obligated as a matter of law to resolve threshold disputes over the elements of a plaintiff's claims, unless a particular determination was necessarily dispositive of the certification question. Because the parties have so requested, however, the court nevertheless addressed several threshold disputes. In regards to the nature of an employer's duty to provide meal periods, the court concluded that an employer's obligation was to relieve its employee of all duty, with the employee thereafter at liberty to use the meal period for whatever purpose he or she desired, but the employer need not ensure that no work was done. Further, in light of the substantial evidence submitted by plaintiffs of defendants' uniform policy, the court concluded that the trial court properly certified a rest break subclass. On the question of meal break subclass certification, the court remanded to the trial court for reconsideration. With respect to the third contested subclass, covering allegations that employees were required to work "off-the-clock," no evidence of common policies or means of proof was supplied, and the trial court therefore erred in certifying a subclass. View "Brinker Restaurant Corp. v. Super. Ct. of San Diego Cty" on Justia Law