Justia Class Action Opinion Summaries

Articles Posted in Supreme Court of Appeals of West Virginia
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The Supreme Court denied a writ of prohibition sought by Petitioner to stop a circuit court's order certifying the underlying case for class action relief, holding that there was no clear legal error in the order.Respondent filed this purported class action alleging asserted causes of action for negligence and seeking various forms of compensatory damages. The circuit court granted Respondent's motion for class certification, and Petitioner petitioned the Supreme Court for a writ of prohibition to halt the circuit court's class certification order. The Supreme Court granted the writ of prohibition. On remand, the circuit court again granted class certification. Petitioner then filed a second petition for a writ of prohibition. The Supreme Court denied the writ, holding that there was no clear error as a matter of law in the circuit court's class certification order. View "Jefferson County Foundation, Inc. v. W. Va. Economic Development Authority" on Justia Law

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The Supreme Court denied a petition requested by West Virginia University Hospitals, Inc. and West Virginia United Health System, Inc. (WVU Hospitals) to invoke the original jurisdiction of the Court to obtain an extraordinary writ of prohibition in relation to a class action that had been pending since 2013, holding that Petitioners failed to show they were entitled to the writ.In their petition for prohibitory relief WVU Hospitals argued that the circuit court violated the express mandate of the Supreme Court as set forth in State ex rel. West Virginia University Hospitals, Inc. v. Gaujot, 829 S.E.2d 54 (W. Va. 2019), by failing to conduct a sufficiently thorough analysis of the factors required for class certification and by failing to give careful consideration to certain ethical issues. The Supreme Court denied the requested writ, holding (1) there was no inadequacy in the circuit court's findings of commonality and ascertainability; and (2) the circuit court was under no obligation to revisit its predominance analysis or the class definition under the Supreme Court's prior mandate. View "State ex rel., West Virginia University Hospitals, Inc v. Honorable Phillip D. Gaujot" on Justia Law

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The Supreme Court granted a writ of prohibition sought by Petitioner to prohibit certification of a class of individuals who received documents from Petitioner containing language that purportedly violated the West Virginia Consumer Credit Protection Act (WVCCPA), W. Va. Code 46A-2-127(g), holding that the circuit court's order did not sufficiency analyze the predominance and superiority factors of W. Va. R. Civ. P. 23(b)(3).Respondents, like the class they proposed to represent, purchased a dissatisfactory HVAC unit from Petitioner. Respondents filed a putative class action alleging that the documents used by Petitioner violated the WVCCPA. The circuit court eventually certified a class action. Petitioner then sought a writ of prohibition challenging the class certification on two grounds. The Supreme Court denied the writ of prohibition as to the first ground but granted it as to the second, holding that the circuit court's order was conclusory as to its analysis of the predominance and superiority factors. View "State ex rel., Dodrill Heating & Cooling, LLC v. Honorable Maryclaire Akers" on Justia Law

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The Supreme Court granted a writ of prohibition prohibiting the circuit court from enforcing an order granting class certification in the underlying civil action filed by Respondents, holding that class certification was improperly granted.The underlying suit arose after an employee of Petitioners - three hospitals, misappropriated the private information of certain patients from Petitioners' medical records during the course of performing her authorized job duties. Respondents - Deborah Welch and Eugene Roman - successfully certified a class of approximately 7,445 individuals. The Supreme Court granted this petition prohibiting the circuit court from enforcing its order granting class certification, holding (1) Welch lacked standing because she suffered no injury-in-fact; and (2) as to Roman and the subclass of 109 individuals he represented, the prerequisites to class certification were not met. View "State ex rel. W. Va. University Hospitals--East, Inc. v. Honorable Hammer" on Justia Law

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The Supreme Court affirmed the judgment of the circuit granting summary judgment for Defendants on all claims contained in Plaintiffs' second amended complaint seeking class certification, relief in mandamus, lost wages, and other monetary damages against six State Offices and their respective officeholders, holding that summary judgment was proper.In 2014, the Legislature amended W. Va. Code 6-7-1, changing the pay cycle for state employees from a semi-monthly to a bi-weekly basis. Plaintiffs, state employees who were paid one pay cycle in arrears pursuant to the provisions of section 6-7-1, claimed that when the statue was amended the result was a taking of five days of salary from every state employee in violation of W. Va. Const. Art. III, 10 or, alternatively, the imposition of a second arrearage beyond what is authorized by the statute. The circuit court granted summary judgment for Plaintiffs. The Supreme Court affirmed, holding that summary judgment was proper. View "Wilkinson v. W. Va. State Office of the Governor" on Justia Law

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The Supreme Court granted as moulded a petition for writ of prohibition sought by Respondent to prohibit the circuit court from conducting any further proceedings in this case until the circuit court vacated its class certification order, holding that the circuit court exceeded its jurisdiction by failing to conduct an appropriate and thorough analysis of the West Virginia Rules of Civil Procedure 23(a) and 23(b) class certification requirements.Respondent, the Honorable Thomas A. Bedell, sitting by assignment as a circuit court judge, certified a class action against Petitioner. Petitioner subsequently filed the instant petition seeking to prohibit enforcement of the class certification order, asserting that the circuit court clearly erred in several respects in certifying the class action. The Supreme Court agreed, holding that the circuit court exceeded its legitimate powers by certifying the class without undertaking a thorough analysis in its determination of whether the class certification requirements of W. Va. R. Civ. P. 23 were satisfied. View "State ex rel. Surnaik Holdings of West Virginia, LLC v. Honorable Thomas Bedell" on Justia Law

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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

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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

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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

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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