Justia Class Action Opinion Summaries

This case involves a class action lawsuit against Logan Health Medical Center ("Logan Health") following a significant data breach of its information technology systems. The breach, which occurred on November 22, 2021, exposed highly sensitive personal identifying information and protected health information of over 200,000 current and former patients and others affiliated with Logan Health. Patricia Tafelski, on behalf of herself and all others similarly situated, filed a complaint against Logan Health. After a series of negotiations, the parties agreed to a settlement of $4.3 million for a common fund. The District Court granted preliminary approval of the proposed settlement on December 6, 2022.The District Court of the Eighth Judicial District, in and for the County of Cascade, granted final approval of the Settlement Agreement, awarded Class Counsel attorney fees, and denied the Objectors’ motion for discovery. The Objectors, Mark Johnson and Tammi Fisher, appealed the order, arguing that the attorney fees of 33.33% of the settlement fund were unreasonable and that their motion for discovery was wrongly denied.The Supreme Court of the State of Montana affirmed the lower court's decision. The court found that the District Court did not abuse its discretion in awarding Class Counsel attorney fees. The court also found that the District Court did not abuse its discretion in denying the Objectors’ motion for discovery. The court noted that the District Court had made adequate findings on each of the factors for determining the reasonableness of attorney fees and that those findings were supported by the record. The court also noted that the District Court had conscientiously considered the nature of the litigation and the interests of the class in denying the Objectors’ motion for discovery. View "Tafelski v. Johnson" on Justia Law

The case involves a class action lawsuit brought by homeowners in the Falcon Ridge subdivision in Billings, Montana, against Buscher Construction and Development, Inc., and other related entities and individuals (collectively referred to as the "Buschers"). The homeowners alleged that the Buschers negligently designed and developed the subdivisions, failed to construct homes to mitigate against the possibility of differential settlement on hydro-collapsible soils, and failed to disclose material adverse facts known to them as the original owners of all the lots within the subdivision.The District Court of the Thirteenth Judicial District, Yellowstone County, certified the class action. The Buschers appealed this decision, arguing that the proposed class did not satisfy the prerequisites for class certification under Montana Rule of Civil Procedure 23(a) and that the court abused its discretion by certifying the class under Rule 23(b)(3).The Supreme Court of the State of Montana affirmed the lower court's decision. The court found that the proposed class satisfied the commonality and typicality requirements of Rule 23(a). The court also found that the class action was superior to other methods for fairly and efficiently adjudicating the controversy, as required by Rule 23(b)(3). The court concluded that the homeowners' claims were not dependent upon individual conduct but on the Buschers' alleged uniform negligence. The court also noted that the lower court has the discretion to revisit certification if class claims no longer predominate as the case proceeds. View "Busher v. Cook" on Justia Law

The Supreme Court affirmed the class certification order entered by the district court against Lewis and Clark County related to the County's practice of conducting strip searches of detainees arrested for non-felony offenses, holding that the district court did not abuse its discretion.Plaintiffs alleged that they were each arrested for a misdemeanor or traffic offenses and that each of them were subjected to a strip search as part of the booking process at the Lewis and Clark County Detention Center without reasonable suspicion to believe they were concealing a weapon or contraband. The district court granted Plaintiffs' motion to certify a class and defined the class to focus on the County’s “policy or practice of conducting strip searches or visual body cavity searches of detainees who may be placed into general custody.” The Supreme Court affirmed, holding that the district court did not certify an overly broad class and did not abuse its discretion by certifying the class action lawsuit. View "Rogers v. Lewis & Clark County" on Justia Law

The Supreme Court affirmed in part the judgment of the district court dismissing Plaintiffs' request for class certification, holding that the district court did not abuse its discretion by holding that Plaintiffs' certification request did not meet the requirements of Mont. R. Civ. P. 23.Plaintiff lived in apartment complexes owned and operated by Defendants. Plaintiffs alleged that their leases contained multiple provisions violating Montana law. Plaintiffs sought certification as a class under Rule 23 to include other tenants who entered into similar lease agreements with Defendants. The district court dismissed most claims but denied the dismissal of two claims as to one plaintiff. The district court also denied Plaintiffs' request for class certification. The Supreme Court affirmed in part and remanded for further proceedings, holding that the district court did not err in dismissing Plaintiffs' request for class certification. View "Vulles v. Thies & Talle Management, Inc." on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court granting class certification in this action alleging breach of contract and violation of Montana's Unfair Trade Practices Act (UTPA), Mont. Code Ann. 33-18-101 et seq., holding that a sufficient factual basis was established to justify certification of the classes.Plaintiffs filed this action against Fergus Farm Mutual Insurance Company (FFM), alleging that FFM breached its insurance contract with Plaintiffs and all other insureds by failing to include general contractor overhead and profit in the cost to repair or replace Plaintiffs' property. The district court granted Plaintiffs' motion for class certification. The Supreme Court reversed in part, holding (1) the district court did not abuse its discretion by determining that common questions of law predominate the litigation and support certification of the class; but (2) certain conclusions reached by the district court were a "bridge too far" at this stage of litigation. View "Kramer v. Fergus Farm Mutual Insurance Co." on Justia Law

The Supreme Court affirmed the order of the district court partially denying Appellant's motion for attorney fees, holding that the district court did not abuse its discretion in its determination of whether attorney fees awarded to class counsel were reasonable.Appellant filed individual and class action claims against Montana University System (MUS). The parties reached a partial settlement. The district court approved the settlement and appointed Appellant the class representative and her attorneys as class counsel. The court's order provided that class counsel were entitled to attorneys' fees and costs, but the parties were unable to agree to a total attorney fees and costs award. The district court declined to award class counsel their requested fees under a percentage-based calculation and, instead, calculated the fee award by multiplying the hours worked on the case by hourly rates of $275 and $375, respectively. The Supreme Court affirmed but remanded the case for a determination of the interest to which Appellant was entitled, holding (1) the district court did not abuse its discretion in determining whether the attorney fees awarded to class counsel were reasonable; and (2) Appellant was entitled to interest in accordance with Mont. Code Ann. 25-9-205. View "Gendron v. Montana University System" on Justia Law

The Supreme Court affirmed in part and reversed in part the orders of the district court certifying three classes to proceed in a lawsuit against the University of Montana, holding that the district court abused its discretion in certifying Class 3 to pursue the claims.Current and former students of the University brought this lawsuit as a class action complaint alleging that the University breached its fiduciary duty to students by entering into a contract with Higher One, Inc. to process student loan refunds through non-competitive financial accounts and by providing students' personal information to Higher One. In two orders, the district court certified three classes to proceed in the lawsuit. The Supreme Court reversed in part, holding (1) the district court's certification of Class 3 under Mont. R. Civ. P. 23(b)(2) was an abuse of discretion; and (2) the district court abused its discretion in certifying Class 1 and Class 2 under Rule 23(b)(1) and (b)(2) but properly certified Class 1 and Class 2 under Rule 23(b)(3). View "Knudsen v. University of Montana" on Justia Law

The Supreme Court affirmed in part the district court’s denial of class certification on the basis that Plaintiff failed to satisfy the Mont. R. Civ. P. 23(b)(3) element of superiority.Plaintiff was terminated at the conclusion of her six-month probationary period due in part to concerns with her background check and credit report. Plaintiff sued the organization that performed the background check, asserting claims in her individual capacity, as well as a claim for class action. The district court determined that Plaintiff met the four rule 23(a) prerequisites but failed to meet her burden regarding the two rule 23(b)(3) requirements of predominance and superiority. The Supreme Court held (1) the district court did not abuse its discretion by denying Plaintiff’s motion for class certification on grounds that she failed to satisfy the superiority requirement, and (2) therefore, there need be no discussion regarding the district court’s holding regarding the predominance requirement. View "Ascencio v. Orion International Corp." on Justia Law

The Supreme Court affirmed three orders of the district court that directed Southwest Montana Building Industry Association (SWMBIA) to transfer funds from the impact fee payer class refund account (refund account) to the City of Bozeman, to submit an accounting of the refund account, and for contempt of court. The Court held (1) the district court did not exceed its authority when it ordered SWMBIA to transfer the funds remaining in the refund account to Bozeman; (2) the district court’s order regarding the transfer of the remaining refund account funds was enforceable; (3) the district court did not err when it did not dispose of the remaining refund account funds in accordance with Mont. R. Civ. P. 23(i)(3); (4) the district court did not abuse its discretion when it ordered SWMBIA to provide an accounting of the refund account; and (5) SWMBIA cannot obtain relief from the district court’s contempt order. View "Southwest Montana Building Industry Ass’n v. City of Bozeman" on Justia Law

Plaintiffs were both insured by USAA Casualty Insurance Company under auto insurance policies that provided medical payments coverage. Plaintiffs filed a complaint against USAA arguing that USAA’s practice of sending medical claims to Auto Injury Solutions (AIS) for review was an improper cost containment scheme designed to deprive Montana consumers of their first-party medical pay benefits. Plaintiffs subsequently filed a motion to certify a proposed class. The district court issued its order certifying the class, concluding “all members of the proposed class were subject to the same claims processing procedure of outsourcing claims to AIS. USAA appealed from the certification order. The Supreme Court reversed, holding that the district court abused its discretion by certifying the class under Mont. R. Civ. P. 23(a) and under Mont. R. Civ. P. 23(b)(3). Remanded. View "Byorth v. USAA Casualty Insurance Co." on Justia Law