Justia Class Action Opinion Summaries

Appellants, current and former shuttle bus drivers at the Minneapolis-St.Paul International Airport, brought suit against appellees in Minnesota state court alleging misclassifications of its drivers as franchisees rather than employees. At issue was whether the district court erred in granting the motion to compel arbitration, erred in enforcing the class action waiver clauses in the drivers' contracts, and erred in dismissing the federal action instead of staying it pending arbitration. The court held that the district court did not err in granting the motion to compel arbitration where appellants agreed to have an arbitrator determine threshold questions of arbitrability and therefore, appellants agreed to have the arbitrator decide whether the Federal Arbitration Act's (FAA), 9 U.S.C. 1, transportation worker exemption applied. The court also held that AT&T Mobility LLC v. Concepcion foreclosed appellants' claim that the district court erred in concluding the class action waivers were enforceable where the Supreme Court recently held that the FAA preempted a state-law-based challenge to the enforceability of class action waivers. The court held that, under the circumstances, the district court abused its discretion in dismissing the action rather than staying it pending completion of the arbitration.

Five hunters commenced this purported class action against A.L.S. Enterprises, and three of its licensees (collectively, defendants), who sell odor absorbing clothing under various brand names in retail stores and mail order catalogs, alleging that defendants violated the Minnesota Consumer Fraud Act (MCFA), Minn. Stat. 325F.69, subd. 1; the Minnesota Unlawful Trade Practices Act (MUTPA), Minn. Stat. 325D.13; and the Minnesota Uniform Deceptive Trade Practices Act (MDTPA), Minn. Stat. 325D.44, subd. 1. Defendants appealed the grant of a permanent injunction, arguing that the district court erred in its literal falsity determinations and in granting an injunction based solely on those determinations. The court held that plaintiffs failed to prove both the requisite irreparable injury and their core allegations that defendants' use of the terms "odor eliminating" and "reactivation" were literally false. Accordingly, the court directed the district court to enter an order dismissing with prejudice all claims for equitable relief. The court held, however, that plaintiffs' individual claims for damages could not be resolved on this summary judgment record. Accordingly, the court remanded for a determination of those claims applying the standards prescribed in Wiegand v. Walser Auto. Groups, Inc.

Plaintiffs, on behalf of a putative class, sued defendant under the Missouri Second Mortgage Loan Act (MSMLA), Mo. Rev. Stat. 408.231-408.241, alleging that defendant charged them unauthorized interest and fees in violation of section 408.233.1 of the MSMLA. At issue was whether defendants violated the MSMLA by charging plaintiffs a loan discount, settlement/closing fee, document processing/delivery fee, and prepaid interest. The court held that plaintiffs did suffer a loss of money when defendant charged the loan discount, although plaintiffs received the loan discount amount two days later as part of a loan disbursement. The court also held that it could not decide whether the loan discount and the settlement/closing fee violated the MSMLA and remanded for further proceedings. The court further held that the document processing/delivery fee was not included in section 408.233's exclusive list of authorized charges and violated the MSMLA. The court finally held that because the processing/delivery free violated the MSMLA, the prepaid interest was an additional violation of the statute. Therefore, the court reversed and remanded to the district court for further proceedings.

Minnesota homeowners brought this action against Zurn Pex, Inc. and Zurn Industries, Inc. (Zurn), alleging that brass fittings used in the company's cross linked polyethylene (PEX) plumbing systems was inherently defective. Zurn appealed the order issued by the district court certifying the warranty and negligence classes. The court held that the district court did not err by conducted a focused Daubert analysis which scrutinized the reliability of the expert testimony in light of the criteria for class certification and the current state of the evidence. In doing so, the district court conducted the requisite "rigorous analysis" of the parties' claims to determine "whether the defendant's liability to all plaintiffs may be established with common evidence." After thoroughly reviewing the record made in the district court in light of the controlling law, the court held that the district court did not commit legal error or abuse its discretion and its class certification was affirmed.

Saint Francis Medical Center ("St. Francis") brought a class action suit against C.R. Bard, Inc. ("Bard"), a supplier of medical supplies, alleging that Bard's contracts with Group Purchasing Organizations violated the Sherman Act, 15 U.S.C. 1, 2, section 3 of the Clayton Act, 15 U.S.C. 14, and Missouri antitrust law, Mo. Rev. Stat. 416.121.1. At issue was whether the district court properly granted summary judgment for Bard. The court held that, based on the precedent of Concord Boat Corp. v. Brunswick Corp., and specifically Saint Francis's failure to identify a relevant submarket, the judgment of the district court granting summary judgment to Bard was affirmed.

Appellants appealed from an order granting summary judgment to appellee on a claim arising under the Worker Adjustment and Retraining Notification Act ("WARN"), 29 U.S.C. 21202, and dismissing without prejudice supplemental state law claims. Appellants alleged that appellee hired them as temporary workers in the midst of a strike and then summarily dismissed them at the strike's conclusion without providing the notice required under the WARN Act. The court held that the district court properly weighed the evidence when determining how to classify the striking workers and did not err in determining that appellants had failed to provided a viable legal theory on which to base its calculations. Moreover, though appellants complained that it was unrealistic to think that 32 striking workers would depart voluntarily, they produced no evidence supporting an alternative scenario. Therefore, appellants' conclusory statements on these issues failed to create a genuine issue of material fact and did not preclude the grant of summary judgment. The court also rejected appellants' claim that the district court erred in considering and rejecting only two of the four theories it proffered where the district court may not have addressed each theory they put forth, but it clearly rejected them all by concluding that the reduction in force was insufficient to satisfy the numerosity threshold. Therefore, the court agreed with the district court that the various theories offered by appellants failed, as a matter of law, to establish that a mass layoff occurred that would trigger notice requirements of the WARN Act. Accordingly, the judgment was affirmed.

T-Mobile Central LLC ("T-Mobile") sued Missouri municipalities for refund of certain tax payments that it had paid under protest and filed ten separate lawsuits seeking to recoup tax payments made within ten specific time periods. Appellees brought ten separate class action suits against T-Mobile in state court for passing the contested tax onto customers and sought to recover any money that the Missouri municipalities refunded to T-Mobile. At issue was whether the district court had jurisdiction under the Class Action Fairness Act ("CAFA"), 28 U.S.C. 1332(d)(6), to remand the ten class actions to the state court from which they were removed. The court affirmed the judgment of the district court and held that there was no indication that appellees artificially divided the lawsuit to avoid the CAFA where the structure of appellees' class actions exactly mirrored the underlying ten lawsuits brought by T-Mobile and were driven by T-Mobile's own litigation decisions.