Justia Class Action Opinion SummariesArticles Posted in U.S. 8th Circuit Court of Appeals
King Cole Foods, Inc., et al v. SuperValu, Inc., et al
Plaintiffs, five retail grocers, each attempting to bring class-action antitrust claims against one of two wholesale grocers, appealed the district court's grant of defendants' motion to dismiss plaintiffs claims from the putative class action. The court held that the non-signatory defendants could not use equitable estoppel to compel arbitration of plaintiffs' claims. Since the district court found the equitable estoppel issue dispositive, it did not address the successor-in-interest argument and therefore, the court remanded for the district court to consider this argument in the first instance. The court concluded that the remaining public policy arguments were moot or the court declined to issue an advisory opinion. View "King Cole Foods, Inc., et al v. SuperValu, Inc., et al" on Justia Law
Luiken, et al v. Domino’s Pizza, LLC
A class of about 1,600 Minnesota delivery drivers employed by Domino's Pizza alleged that, under Minnesota law, a fixed delivery charge that customers paid Domino's was a gratuity wrongfully withheld from them. The court held that the varied context of the pizza delivery transactions made it unreasonable for some customers to construe the delivery charge as a payment for personal services, thereby preventing one-stroke determination of a classwide question. Therefore, the district court abused its discretion by certifying the class. Accordingly, the court reversed the class certification order and remanded for further proceedings. View "Luiken, et al v. Domino's Pizza, LLC" on Justia Law
Owen v. Bristol Care, Inc.
Bristol Care appealed the denial of its motion to compel arbitration in a suit initiated by its former employee asserting claims under the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq., and seeking class action certification. Given the absence of any contrary congressional command from the FLSA that a right to engage in class actions overrides the mandate of the Federal Arbitration Act, 9 U.S.C. 3-4, in favor of arbitration, the court held that arbitration agreements containing class waivers were enforceable in claims brought under the FLSA. Because the court concluded that the Mandatory Arbitration Agreement (MAA) signed by the employee and Bristol Care was enforceable, the court reversed the district court's decision and directed the district court to enter an order granting Bristol Care's motion to stay proceedings and compel arbitration. View "Owen v. Bristol Care, Inc." on Justia Law
Jacks v. Meridian Resource Co., et al
This case principally involved challenges to the application, in Missouri, of the provision of the Plan administered by BCBS-KC that required a Plan enrollee who received benefits in connection with any injury in addition to compensation from a third party must reimburse BCBS-KC the amount of benefits paid. Given the state's antisubrogration laws, plaintiff contended that BCBS-KC was unable to recover its reimbursement liens in Missouri. BCBS-KC removed the action to federal district court and plaintiff then moved to remand the matter to state court. BCBS-KC subsequently appealed the district court's remand based upon the local controversy exception to the Class Action Fairness Act (CAFA), 28 U.S.C. 1332(d); its determination that federal common law was not contemplated in this action; and its decision that BCBS-KC could not remove this matter under the federal officer removal statute. Because the court determined that this matter was properly in federal court under the federal officer removal statute, the court need not address plaintiff's remaining claims. That said, the court did not delve into the CAFA claim, but rather reversed the district court's judgment and remanded this matter for further consideration, directing that this action remain in federal court. View "Jacks v. Meridian Resource Co., et al" on Justia Law
New Millennium Consulting, et al v. United Healthcare Services
United HealthCare hired Chimes, a centralized vendor management company, to assist it with the procurement and management of contingent workers. Chimes entered into supplier contracts with New Millennium and Pacific Management, among others, to provide the contingent labor to United HealthCare. New Millennium and Pacific Management brought this putative class action against United HealthCare, alleging that it was liable to them and other suppliers for the unpaid bills as the principal of Chimes. Because Chimes was not an agent of United HealthCare under prevailing Minnesota law, the court affirmed the district court's denial of class certification and grant of summary judgment to United HealthCare. View "New Millennium Consulting, et al v. United Healthcare Services" on Justia Law
McCrary v. Stifel, Nicolaus & Co.
Two individuals brought suit as individuals and on behalf of a putative class of investors, alleging that Stifel, Nicolaus & Co. (Stifel) and two of its employees, Neil Harrison and Roger Compton, violated federal securities law. Stifel and Compton (Defendants) filed a motion to dismiss for failure to state a claim under Fed. R. Civ. P. 12(b)(6) and the Private Securities Litigation Reform Act of 1995 (PSLRA). The district court concluded that Plaintiffs' allegations failed to satisfy the requirements for class action claims under Fed. R. Civ. P. 23(b)(3) and dismissed Plaintiffs' compliant with prejudice. The Eighth Circuit Court of Appeals (1) reversed the district court's order with respect to Plaintiffs' individual claims, holding the district court erred in dismissing the claims without either staying the claims pending arbitration or undertaking an analysis of the claims under the PSLRA; and (2) affirmed the district court's order as it applied to Plaintiffs' class claims, holding that the court correctly determined that the complained failed to state viable class claims under Rule 23. Remanded. View "McCrary v. Stifel, Nicolaus & Co." on Justia Law
Rashaw v. United Consumers Credit Union
Four named plaintiffs filed three separate class action lawsuits in state court alleging, inter alia, that three Missouri credit unions, by participating in a subprime motor vehicle lending and investment program administered by now-bankrupt Centrix Financial, LLC, violated provisions of the Missouri Uniform Commercial Code (Mo UCC) and the Missouri Merchandising Practices Act (MMPA). Defendants removed under the Class Action Fairness Act and moved to dismiss the complaints. The district court issued three identical orders dismissing all the state law claims. The Eighth Circuit Court of Appeals consolidated the three appeals and affirmed, holding that plaintiffs' Mo UCC claims were time-barred and that the MMPA expressly exempted Missouri credit unions. View "Rashaw v. United Consumers Credit Union" on Justia Law
Public Pension Fund Group, et al. v. KV Pharmaceutical Co., et al.
Plaintiffs, groups of investors who purchased the securities of KV, brought this class action lawsuit alleging that KV and some of its individual officers committed securities fraud. Plaintiffs alleged that KV made false or misleading statements about its compliance with Food and Drug Administration (FDA) regulations governing the manufacture of pharmaceutical products, and made false or misleading statements about earnings resulting from pharmaceutical products allegedly manufactured in violation of FDA regulations. The court concluded plaintiffs' complaint adequately set forth the reasons why KV's statements about is compliance were false, or at least misleading, at the time they were made; the district court did not err when it determined the investors' complaint did not sufficiently plead that KV made false or misleading statements about earnings tied to the manufacture of generic Metoprolol; the district court correctly dismissed the scheme liability claims against the two individual KV officers; but the district court erred in denying the motion to amend the complaint. Accordingly the court affirmed in part, reversed in part, and remanded for further proceedings. View "Public Pension Fund Group, et al. v. KV Pharmaceutical Co., et al." on Justia Law
E-Shops Corp. v. U.S. Bank Nat’l Assoc.
E-Shops filed a class action complaint, after receiving a number of chargebacks resulting from fraudulent use of U.S. Bank credit cards, alleging that U.S. Bank knowingly allowed itself to be an instrument of the fraud, thereby making E-Shop's performance under its contract with its merchant bank more expensive. The district court dismissed E-Shops complaint for failure to state a claim. The court affirmed, holding that E-Shops failed to satisfy the required pleading standards. View "E-Shops Corp. v. U.S. Bank Nat'l Assoc." on Justia Law
Professional Firefighters Assoc., et al. v. Zalewski
Appellant, as counsel for a group of 64 retired city firefighters and their families, appealed the district court's approval of a class-action settlement agreement between the city and a certified class of active and retired firefighters, police officers, civilian employees, and their unions. The court held that, given the nature of the case and the potential conflict at issue, the district court did not abuse its discretion in certifying the class or by ensuring fair and adequate representation for the entire class by means other than appointing separate counsel for each subclass. The district court's conclusion that the settlement agreement was a fair, reasonable, and adequate settlement for all of the class members was well within its discretion. Finally, the court rejected appellant's argument that the district court abused its discretion under Rule 23(d) by failing to hold a special hearing on the ability of class counsel to represent the subclass. Accordingly, the court affirmed the judgment. View "Professional Firefighters Assoc., et al. v. Zalewski" on Justia Law