Justia Class Action Opinion SummariesArticles Posted in U.S. 11th Circuit Court of Appeals
Faught, et al. v. Shepard, et al.
This appeal was the consolidation of four appeals brought by objectors to a class action settlement. The underlying case involved allegations that AHS engaged in a pattern of wrongfully denying claims under its home warranty contracts. Two class action lawsuits resulted from these allegations: the first was brought in California state court (Edleson Action) and this case, originally filed in the Northern District of Alabama. After the California court rejected a proposed settlement in the Edleson Action, the parties in this case reached a settlement agreement, which the district court approved. Four sets of objectors appealed. The court held that the district court did not abuse its discretion in finding that the reference to the Edleson agreement and the other information at issue provided reasonable notice under the circumstances. The court also held that the district court did not abuse its discretion when it reviewed the validity of the settlement action and rejected objectors' claims to the contrary. The court finally held that the district court did not abuse its discretion in awarding attorneys' fees. Accordingly, the judgment of the district court was affirmed.
Edleson, et al. v. American Home Shield Corp., et al.
This appeal involved a fundamental misunderstanding about the enforcement of an injunction. The district court approved a settlement between defendant and a national class represented by plaintiffs, as part of its judgment, enjoined permanently "anyone claiming... for the benefit of" members of the class for prosecuting released claims. Movants opted out of the settlement of that class action, but continued to prosecute a putative class action against defendant in a California court. Instead of moving the district court to enforce its extant injunction, defendant then moved the district court to enter another injunction to bar movants from prosecuting their putative class action in the California court, under the All Writs Act, 28 U.S.C. 2283. The district court granted that motion and entered a second injunction, which movants now challenge on appeal. The court held that because the district court failed to comply with "equity's time-honored procedures" to enforce an injunction, the second injunction against movants was vacated and remanded for further proceedings.
Lawson, et al. v. Life of the South Ins. Co.
This case arose when plaintiffs filed a nationwide consumer class action against Life of the South Insurance Company (Life of the South). At issue was whether Life of the South had a right to enforce against plaintiffs the arbitration clause in the loan agreement, between plaintiffs and the car dealership where they purchased their vehicle, where the loan agreement lead plaintiffs to enter into a separate credit life insurance contract with Life of the South. The court held that the loan agreement did not show, on its face or elsewhere, an intent to allow anyone other than plaintiffs, the car dealership, and Chase Manhattan, and the assignees of the dealership of Chase Manhattan, to compel arbitration of a dispute and Life of the South was none of those. The court also held that because the only claims plaintiffs asserted were based on the terms of their credit life insurance policy with Life of the South, which did not contain an arbitration clause, equitable estoppel did not allow Life of the South to compel plaintiffs to arbitrate. Accordingly, the court affirmed the district court's denial of Life of the South's motion to compel arbitration.
Amer. Assoc.of People with Disabilities, et al. v. Harris, et al.
Plaintiffs, visually or manually impaired Florida citizens who were registered to vote in Duval County, Florida and were represented by the American Association of People with Disabilities, filed a putative class action against defendants, alleging that defendants violated federal statutory and state constitutional provisions by failing to provide handicapped-accessible voting machines to visually or manually impaired Florida voters after the 2000 general election. The court vacated its prior opinion and in its revised opinion, held that the district court erroneously granted plaintiffs' requested declaratory judgment and injunction against purported violations of the American with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101-12213, and the regulations promulgated thereunder. The opinion, however, based that outcome exclusively on the ground that voting machines were not "facilities" under 28 C.F.R. 35.151(b).
Baptista v. JPMorgan Chase Bank, N.A.
Plaintiff filed a class action suit against JP Morgan Chase Bank ("Chase") alleging violations of Fla. Stat. 655.85 and unjust enrichment where she was charged a fee to cash a check as a non-account holder at Chase. At issue was whether the district court properly granted Chase's motion to dismiss both plaintiff's claims as preempted by the National Bank Act ("NBA"), 12 U.S.C. 21 et seq. The court affirmed dismissal where Fla. Stat. 655.85 was preempted by the Office of Comptroller of the Currency's ("OCC") regulations promulgated pursuant to the NBA where Congress clearly intended that the OCC be empowered to regulate banking and banking-related services. The court also held that because plaintiff's unjust enrichment claim relied on identical facts as her claim under the state statute, it too was preempted.