Justia Class Action Opinion Summaries

Two individuals who stayed at a San Dimas hotel challenged the hotel’s practice of enforcing a maximum 28-day stay policy. Under this policy, guests were required to check out and completely vacate the property for at least three days before being permitted to re-register, a practice the hotel’s management acknowledged was intended to avoid creating landlord-tenant relationships. The plaintiffs, who stayed at the hotel multiple times between June and November 2022, brought a putative class action alleging violations of California Civil Code section 1940.1 and other related claims, arguing that the hotel’s policy was designed to circumvent tenant protections for those using the hotel as a primary residence.The plaintiffs moved to certify a class consisting of all individuals who stayed at the hotel for at least 28 consecutive days but fewer than 31 days, from late 2018 to the present. The Superior Court of Los Angeles County found the class was numerous, ascertainable, and that the plaintiffs’ claims were typical, but denied class certification. The trial court reasoned that individualized questions predominated, because it believed section 1940.1 required proof that each class member used the hotel as their “primary residence” for the hotel to qualify as a “residential hotel” under the statute.The California Court of Appeal, Second Appellate District, Division Three, reviewed the order. The appellate court held that the trial court erred by interpreting section 1940.1 to require individualized proof that each guest used the hotel as their primary residence. The court clarified that whether a hotel is a “residential hotel” under section 1940.1 is a question that focuses on the overall character and intended use of the hotel, not on each individual guest’s circumstances. The order denying class certification was reversed, and the matter was remanded for the trial court to revisit the class certification question under the correct legal standard. View "Aerni v. RR San Dimas" on Justia Law

Several home builder companies challenged fees they were required to pay to a city when connecting to municipal water and sewer systems. These so-called Capital Facilities Fees were imposed as a condition of development between 2016 and 2018. The builders paid these fees directly to the city and allege that the charges were not authorized by state law. They sought to recover the payments and also requested to represent a class of all entities who, like them, paid the fees during the relevant period.In Superior Court, Wake County, the plaintiffs moved for class certification, arguing that their claims and those of other payors shared common legal and factual questions. The trial court certified a class including all entities who paid the fees between January 2016 and June 2018, finding that the class was numerous, the claims predominated over individual differences, and class treatment was the superior method for resolving the dispute. The trial court also granted summary judgment to the plaintiffs on the merits, but the city appealed only the class certification order directly to the Supreme Court of North Carolina.The Supreme Court of North Carolina considered only whether class certification was proper. It held that, under the applicable state statute, the right to a refund depends on who made payment to the city, not on who ultimately bore the cost. The possibility that some builders incorporated the fees into home prices did not defeat class certification, as the statute entitles the actual payor to relief. The court concluded that the trial court correctly applied the legal criteria for class certification and did not abuse its discretion. The order certifying the class was therefore affirmed. View "Wardson Constr., Inc. v. City of Raleigh" on Justia Law

A group of Carteret County property owners challenged the county’s policy of charging waste disposal fees. The county does not provide direct trash or recycling collection services but instead offers access to waste disposal sites and a landfill. The county funded these facilities by charging fees to property owners, including both those who potentially used the county sites and those who hired private waste collection services. The plaintiffs argued that the county unlawfully charged these fees to property owners who never used the county sites or who had private waste collection, and also that the total fees collected exceeded the cost of operating the facilities, in violation of state law.Following extensive discovery, the Superior Court in Carteret County considered plaintiffs’ motion for class certification. The court rejected one proposed class, finding that determining whether each property owner actually used a county site would require individualized inquiries that would predominate over common issues. However, the court certified three other classes: those allegedly charged fees despite using private waste collection services, and those asserting that the county collected fees beyond its actual operating costs. The county appealed the class certification order directly to the Supreme Court of North Carolina. The plaintiffs did not cross-appeal the denial of the first class.The Supreme Court of North Carolina affirmed the Superior Court’s class certification order. The Court held that it is feasible to ascertain class members who used private waste collection services by relying on the customer lists from the limited number of providers in the county. The Court also determined that issues of predominance and superiority did not bar class certification and that any future developments could be addressed through modification or decertification of the class. Thus, the trial court’s order was affirmed. View "Armistead v. County of Carteret" on Justia Law

An assisted living residence operated by the defendant charged new residents a one-time “community fee” upon admission. The agreement stated that this fee was intended to cover upfront staff administrative costs, the resident’s initial service coordination plan, move-in assistance, and to establish a reserve for building improvements. The plaintiff, acting as executor of a former resident’s estate and representing a class, alleged that this community fee violated the Massachusetts security deposit statute, which limits the types of upfront fees a landlord may charge tenants. The complaint further claimed that charging the fee was an unfair and deceptive practice under state consumer protection law.The Superior Court initially dismissed the case, finding that the security deposit statute did not apply to assisted living residences, which are governed by their own regulatory scheme. On appeal, the Supreme Judicial Court of Massachusetts previously held in a related decision that the statute does apply to such residences when acting as landlords, but does not prohibit upfront fees for services unique to assisted living facilities. The court remanded the case for further factual development to determine whether the community fee corresponded to such services. After discovery and class certification, both parties moved for summary judgment. The Superior Court judge ruled for the plaintiffs, finding that the community fees were not used solely for allowable services because they were deposited into a general account used for various expenses, including non-allowable capital improvements.On direct appellate review, the Supreme Judicial Court of Massachusetts reversed. The court held that the defendant was entitled to judgment as a matter of law because uncontradicted evidence showed that the community fees corresponded to costs for assisted living-specific intake services that exceeded the amount of the fees collected. The court emphasized that the statute does not require the fees to be segregated or tracked dollar-for-dollar, and ordered judgment in favor of the defendant. View "Ryan v. Mary Ann Morse Healthcare Corp." on Justia Law

A purchaser of a home paid off an existing mortgage at closing, which triggered a statutory obligation for the lender to record a release of the mortgage within 90 days. The lender failed to record the release by the deadline, recording it 22 days late. The statute at issue provides that if a lender does not timely record the release, the borrower and current owner may seek $250 in statutory damages. After the lender’s late recordation, the owner filed suit seeking those damages and, in addition, sought to represent a class of similarly situated individuals whose lenders had not timely recorded mortgage releases.The dispute was initially removed to the United States District Court for the Southern District of Ohio, but that court remanded the case to state court for lack of subject-matter jurisdiction. The Hamilton County Court of Common Pleas denied the lender’s motion for summary judgment, finding the owner had standing, and granted the owner’s motion to certify a class. At that time, an amendment to the statute barring class actions for such statutory damages had been enacted but not yet effective, so the trial court applied the prior version. The First District Court of Appeals affirmed, finding the owner had statutory standing and that the amended statute did not apply retroactively to bar the class.The Supreme Court of Ohio reviewed the case and held that the statute confers standing consistent with the Ohio Constitution, allowing the owner’s individual claim for statutory damages. However, the court further held that the 2023 amendment, which bars class-wide recovery of statutory damages for violations occurring in 2020, is remedial and applies retroactively to this case. The court found that the lower courts erred by not applying the amended statute and by certifying the class. The Supreme Court of Ohio affirmed in part and reversed in part, remanding with instructions to decertify the class. View "Voss v. Quicken Loans, L.L.C." on Justia Law

The plaintiffs in this case are trustees who own a property in Kīhei, Maui, which they use as a vacation home for personal use. In 2021, Maui County reclassified their property as a “short-term rental” based solely on zoning, not actual use, resulting in a higher property tax rate. The plaintiffs paid the assessed taxes but did not utilize the administrative appeals process available through the Maui County Board of Review. Instead, they filed a class action in the Circuit Court of the Second Circuit, seeking a refund and alleging that the County’s collection of the higher taxes was unconstitutional, violated due process, and resulted in unjust enrichment.The Circuit Court of the Second Circuit granted the County’s motion to dismiss, finding it lacked subject matter jurisdiction. The court determined that under Hawai‘i Revised Statutes chapter 232 and Maui County Code chapter 3.48, the proper procedure for contesting real property tax assessments—including constitutional challenges—requires first appealing to the County Board of Review and, if necessary, then to the Tax Appeal Court. Because the plaintiffs bypassed these required steps and missed the statutory deadline to appeal, the court dismissed the case with prejudice.On appeal, the Supreme Court of the State of Hawai‘i affirmed the circuit court’s dismissal. The Supreme Court held that the Tax Appeal Court has exclusive jurisdiction over appeals regarding real property tax assessments, including those raising constitutional issues, and found that the plaintiffs’ claims were time-barred due to their failure to timely pursue the established administrative remedies. As a result, the Supreme Court affirmed the circuit court’s judgment dismissing the plaintiffs’ claims for lack of subject matter jurisdiction. View "Piezko v. County of Maui" on Justia Law

A developer challenged the legality of “recreation fees” imposed by a municipality on builders of new subdivisions. The developer argued that the town’s fees, charged in lieu of dedicating land for public recreation, either exceeded statutory limits or were unconstitutional because they were not proportionate to each development’s impact. The developer further alleged that the municipality did not use the fees as required, instead commingling them with general funds and failing to create or improve public recreation areas near the developments.In the Superior Court of Wake County, the developer pursued a putative class action seeking declaratory relief and a refund of all such fees paid since November 2017. The Superior Court certified a class including all payers of the recreation fees, finding several common legal questions appropriate for resolution on a class-wide basis. These included whether the fees violated statutory requirements, whether their calculation was legally proper, whether their use complied with statutory mandates, and whether they were constitutionally proportionate. The municipality appealed directly to the Supreme Court of North Carolina, arguing that individualized factual inquiries predominated over common issues and that a class action was not the superior method of adjudication.The Supreme Court of North Carolina held that the class as certified did not satisfy the predominance requirement for class actions. The Court explained that several claims—such as whether fees exceeded fair market value or were roughly proportional—would require individualized, fact-intensive determinations for each class member, resulting in mini-trials that would overwhelm the common legal issues. Consequently, the Supreme Court vacated the trial court’s class certification order and remanded for further proceedings, instructing the lower court to reconsider class certification in light of these findings. View "Empire Contractors Inc. v. Town of Apex" on Justia Law

The case concerns challenges to groundwater replenishment charges imposed by a water district in a desert region where groundwater is the main source of potable water. The water district operates three areas of benefit (AOBs) and levies replenishment charges on customers who pump significant groundwater. Domestic customers do not pay these charges directly, but their payments for drinking water are allocated to the replenishment funds through the district’s enterprise fund system. Plaintiffs, including a taxpayer association, alleged that the replenishment charges were unconstitutionally structured, resulting in higher rates for certain AOBs and unfair subsidies for others, benefitting large agricultural businesses.The litigation began with a combined petition and class action in the Superior Court of Riverside County, which was dismissed because the court found the validation statutes applied and the statute of limitations had expired. Subsequent reverse validation actions for later fiscal years were timely filed and consolidated. The Superior Court, in rulings by two judges, found the replenishment charges to be unconstitutional taxes because they did not satisfy the requirements of California Constitution Article XIII C, Section 1, subdivision (e)(2). Specifically, the court found that the district failed to show the allocation of replenishment costs bore a fair or reasonable relationship to the burdens or benefits received by each AOB, and thus the charges were not exempt from being classified as taxes. The court awarded substantial refunds to affected ratepayers and enjoined the district from imposing similar unconstitutional charges in the future.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed both the district’s appeal of the remedies and liability findings and the taxpayer association’s cross-appeal on procedural grounds. The appellate court affirmed in full, holding that the replenishment charges were unconstitutional, the remedies were proper, and that the validation statutes applied to these charges, thus barring untimely claims for earlier years. The appellate court also found no error in the trial court’s grant of refund and injunctive relief. View "Howard Jarvis Taxpayers Assn. v. Coachella Valley Water Dist." on Justia Law

Cocoa AJ Holdings, LLC is the developer of a mixed-use condominium project in San Francisco known as GS Heritage Place, which includes both timeshare and whole residential units. Stephen Schneider owns a timeshare interest in one of the fractional units and has voting rights in the homeowners association. In 2018, Schneider filed a class action lawsuit against Cocoa and others, alleging improper management practices, including the use of fractional units as hotel rooms and misallocation of expenses. The parties settled that lawsuit in 2020, with Schneider agreeing not to disparage Cocoa or solicit further claims against it, and to cooperate constructively in future dealings.In 2022, Schneider initiated another lawsuit against Cocoa. In response, Cocoa filed a cross-complaint against Schneider, alleging intentional interference with prospective economic advantage, breach of contract (the settlement agreement), unjust enrichment, and defamation. Cocoa claimed Schneider engaged in a campaign to prevent the sale of unsold units as whole units, formed unofficial owner groups, made disparaging statements, and threatened litigation, all of which allegedly violated the prior settlement agreement and harmed Cocoa’s economic interests.Schneider moved to strike the cross-complaint under California’s anti-SLAPP statute (Code of Civil Procedure section 425.16), arguing that Cocoa’s claims arose from his protected activities—namely, petitioning the courts and speaking on matters of public interest related to association management. The Superior Court of the City and County of San Francisco granted Schneider’s motion, finding that all claims in the cross-complaint arose from protected activity and that Cocoa failed to show a probability of prevailing on the merits.The California Court of Appeal, First Appellate District, Division Three, affirmed the trial court’s order. The court held that Cocoa’s claims were based on Schneider’s protected litigation and association management activities, and that Cocoa did not establish a likelihood of success on any of its claims. View "Cocoa AJ Holdings, LLC v. Schneider" on Justia Law

After a series of chemical explosions at an industrial plant in Crosby, Texas, following Hurricane Harvey, property owners and lessees in the affected area experienced contamination and property damage. These individuals, including the appellants, initially participated in a federal class action seeking both injunctive and monetary relief for the harm caused by the explosions. The federal district court certified a class for injunctive relief but declined to certify a class for monetary damages. Subsequently, a class settlement addressed only injunctive relief, leaving monetary claims unresolved.Following the settlement, nearly 800 class members, including the appellants, filed individual lawsuits in Texas state court seeking monetary damages for their property-related claims. The appellants acknowledged that their claims accrued in September 2017 and were subject to a two-year statute of limitations, but argued that the pendency of the federal class action tolled the limitations period under Texas law. Arkema, the defendant, removed the cases to the United States District Court for the Southern District of Texas and moved to dismiss, asserting that Texas does not recognize cross-jurisdictional tolling—meaning a federal class action does not toll the state statute of limitations. The district court consolidated the cases and dismissed the claims as untimely, relying on Fifth Circuit precedent.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the dismissal de novo. The court held that, under its binding precedent, Texas law does not permit cross-jurisdictional tolling of statutes of limitations based on the pendency of a federal class action. The court rejected the appellants’ arguments for exceptions to this rule and found no intervening Texas authority to the contrary. Accordingly, the Fifth Circuit affirmed the district court’s dismissal of the appellants’ claims as time-barred. View "Ackerman v. Arkema" on Justia Law