Justia Class Action Opinion Summaries

Articles Posted in Supreme Court of Appeals of West Virginia
by
The Supreme Court granted the writ of prohibition requested by Petitioner, Municipal Water Works, to challenge a circuit court order granting Respondents' motion for class certification, holding that the order granting class certification must be vacated because the circuit court failed to conduct a thorough analysis of the four class certification prerequisites in Rule 23(a) of the West Virginia Rules of Civil Procedure. Respondents, individually and on behalf of a class of similarly situated individuals, filed a complaint against Municipal Water alleging that each putative class members was a customer of Municipal Water and, as a result, was exposed to illness causing pollutants in their water supply. Respondents filed a motion for class certification, which the circuit court granted. Petitioner then sought a writ of prohibition arguing that the circuit court's order did not contain a "thorough analysis" explaining how Respondents satisfied the four prerequisites contained in Rule 23(a). The Supreme Court agreed and granted the writ, holding that the circuit court's order did not contain a thorough analysis of the Rule 23(a) factors. View "State ex rel., Municipal Water Works v. Honorable Derek Swope" on Justia Law

by
The Supreme Court granted a writ of prohibition sought by Municipal Water Works to challenge an order issued by the circuit court granting Plaintiffs' motion for class certification, holding that the circuit court failed to conduct a thorough analysis of the class prerequisites in W. VA. R. Civ. P. 23(a), and therefore, the order granting class certification must be vacated. Plaintiffs, individually and on behalf of a class of individuals that were customers of Municipal Water, filed a complaint in the circuit court alleging that each putative class member was exposed to illness-causing pollutants in their water supply. After a hearing, the circuit court entered an order granting class certification. The Supreme Court vacated the order, holding that the circuit court's order did not contain a thorough analysis of the Rule 23(a) factors. View "State ex rel. Municipal Water Works v. Honorable Derek C. Swope" on Justia Law

by
The Supreme Court vacated the order of the circuit court denying two hospitals' motion to decertify the class after the court initially certified a class action against the hospitals, holding that the circuit court exceeded its jurisdiction by failing to conduct a sufficiently thorough analysis of whether the commonality required for class certification under W. Va. R. Civ. P. 23 was present. Respondent Phillip Gaujot, a judge of the circuit court, certified the class action against West Virginia University Hospitals, Inc. and West Virginia United Health System, Inc. The hospitals moved to decertify the class, but the Judge Gaujot denied the motion. The hospitals then filed a petition for a writ of prohibition asking the Supreme Court to prohibit Judge Gaujot from conducting any further proceedings until he vacated his order denying their motion to decertify the class. The Supreme Court granted the writ of prohibition as moulded, holding that the circuit court exceeded its legitimate powers by certifying the class while failing to conduct a sufficiently thorough analysis of the case to determine whether the commonality required for class certification under Rule 23 was present. View "State ex rel. West Virginia University Hospitals, Inc. v. Honorable Phillip D. Gaujot" on Justia Law

by
In this ancillary statutory proceeding in aid of collection on a judgment, the Supreme Court affirmed the ruling of the circuit court awarding summary judgment in favor of Respondents. Respondents were previously awarded a judgment against Employer in a class action alleging violations of the West Virginia Wage Payment and Collection Act. Respondents later caused a suggestion a personal property to be served upon Petitioner in which they sought amounts, obligations, and things of value owed to Employer. Respondents then sought to make Petitioner liable for Respondents’ judgment. The circuit court granted, in part, the motion to make Petitioner liable for Respondents’ judgment and then directed Petitioner to pay Respondents the amount of their judgment against Employer. The Supreme Court affirmed, holding that summary judgment was proper where Petitioner’s contractual obligations to Employer were subject to Respondents’ suggestion and where West Virginia law provides for suggestion upon unmatured debts. View "IPacesetters, LLC v. Douglas" on Justia Law

by
Respondent filed a putative class action alleging that Petitioner had failed to pay him and other similarly situated employees their final wages within the time period mandated by the West Virginia Wage Payment and Collection Act. Respondent served requests upon Petitioners seeking class discovery. Petitioner filed a motion to stay class discovery, arguing that the class discovery was overly broad, unduly burdensome, and premature. The circuit court denied the request to stay class discovery, finding that Petitioner had waived its objections to class discovery, as they were untimely raised, and had further failed to meet its burden of demonstrating why such discovery should not proceed. Petitioner appealed the circuit court’s interlocutory order and invited the Supreme Court to extend the collateral order doctrine to interlocutory discovery orders that implicate case management. The Court, however, chose to consider this matter as a petition for a writ of prohibition, granted the writ, and vacated the order denying Petitioner’s motion to stay class discovery, holding that the circuit court abused its discretion in refusing to stay class discovery pending a ruling on the threshold legal issue of statutory construction that bears on the viability of Respondent’s individual claim. Remanded. View "GMS Mine Repair & Maintenance, Inc. v. Milkos" on Justia Law

by
Plaintiffs, on behalf of themselves and others similarly situated, were former students in the nursing program at Salem International University (Salem). When Plaintiffs enrolled, they signed enrollment agreements that contained an arbitration clause. Plaintiffs filed a putative class action complaint against Salem and its president (collectively, Salem) alleging that they were denied the opportunity to complete their coursework in nursing at Salem as a result of the nursing program’s loss of accreditation. Salem filed a motion to stay proceedings pending mandatory alternative dispute resolution. The circuit court denied the motion, concluding that the arbitration agreement did not include an enforceable class action litigation waiver. The Supreme Court reversed, holding that the arbitration agreement acted as a class action litigation waiver barring Plaintiffs from seeking judicial relief as a class. View "Salem International University v. Bates" on Justia Law