Articles Posted in U.S. Court of Appeals for the Eleventh Circuit

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Plaintiffs filed suit alleging that defendants operated a racketeering enterprise through which they performed and billed for unnecessary heart procedures. The district court dismissed the case. At issue on appeal was whether the Class Action Fairness Act's local-controversy provision, (CAFA), 28 U.S.C. 1332(d)(4), precluded the district court from exercising federal-question jurisdiction. If not, the court must decide whether plaintiffs alleged that they were injured in their "business or property," under the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. 1964(c). The court affirmed the denial of plaintiffs' motion to remand because CAFA's local-controversy provision does not prohibit district courts from exercising federal-question jurisdiction under 28 U.S.C. 1331. However, the court vacated the district court's grant of defendants' motion to dismiss because plaintiffs alleged economic injuries that were recoverable under RICO. View "Blevins v. Seydi V. Aksut, M.D." on Justia Law

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Wright filed suit in federal court against Pilot, alleging that Pilot and certain Pilot employees systematically shortchanged some trucking companies with whom Pilot had discount agreements by failing to give them the agreed-upon benefits. Wright filed claims under both state and federal law. At issue here is whether federal courts that are given original subject-matter jurisdiction over state-law claims by the Class Action Fairness Act (CAFA), 28 U.S.C. 1332(d), retain that jurisdiction even when the class claims are dismissed before the class is certified. The district court found that CAFA does not vest the federal courts with original jurisdiction over state-law claims after the class claims are dismissed. Pilot argues that CAFA conferred original jurisdiction over all of Wright’s claims at the time Wright filed them, such that the jurisdiction could not have divested when the class claims were later dismissed. Here, Wright first filed directly in federal court under CAFA but now wishes to refile in state court. When the post-filing action that did away with the class claims is not an amendment to the complaint, the court saw no basis for distinguishing cases originally filed in federal court under CAFA from those removed to federal court. Therefore, the court concluded that CAFA continues to confer original federal jurisdiction over the remaining state-law claims in this suit. Because CAFA vested the district court with original jurisdiction over the remaining claims, there was no need for it to analyze supplemental jurisdiction. Accordingly, the court reversed and remanded. View "Wright Transportation, Inc. v. Pilot Corporation" on Justia Law

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General Motors challenged the district court's order granting in part a motion for class certification in an action brought by plaintiffs under the Florida Deceptive and Unfair Trade Practices Act (FDUTPA), Fla. Stat. 501.201 et seq. The district court certified a class consisting of all Florida purchasers and lessees of 2014 Cadillac CTS sedans. In this case, the district court found the predominance requirement to be satisfied by an essential question common to each class member: whether the inaccurate Monroney sticker provided by General Motors constituted a misrepresentation prohibited by FDUTPA. The court concluded that, by inaccurately communicating that the 2014 Cadillac CTS had attained three perfect safety ratings, General Motors plainly obtained enhanced negotiating leverage that allowed it to command a price premium. The size of that premium represents the damages attributable to that theory of liability. Because that theory is consistent for all class members, the predominance requirement under Federal Rule of Civil Procedure 23(b)(3) is satisfied. This consistency is also sufficient to establish the commonality requirement under Rule 23(a)(2). Because common questions of law and fact predominate, class-wide adjudication appropriately conserves judicial resources and advances society’s interests in judicial efficiency. Finally, the court rejected General Motor's contention that plaintiff failed to prove that she can fairly and adequately protect the interests of the class. Because the district court did not abuse its discretion in certifying the class, the court affirmed the judgment. View "Carriuolo v. General Motors Co." on Justia Law

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Plaintiffs, consumers from California and Texas, filed class actions against Electrolux, the manufacturer of front-loading washing machines, alleging warranty and consumer claims. Specifically, plaintiffs allege that the rubber seal on the front door of the machines retains water, allowing mildew to grow, causing stains on clothing, and creating a foul odor. The court concluded that the district court abused its discretion in assessing predominance and therefore vacated the class certification. On remand, the district court should revisit Electrolux's argument that the consumer claims do not satisfy predominance because plaintiffs cannot prove causation on a classwide basis, and the district court abused its discretion by certifying the warranty claims without first resolving preliminary questions of state law that bear on predominance. The court further concluded that plaintiffs' damages do not necessarily defeat predominance, and Electrolux's defense of misuse does not necessarily defeat predominance. Accordingly, the court vacated and remanded. View "Brown v. Electrolux Home Products, Inc." on Justia Law

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Plaintiffs, consumers from California and Texas, filed class actions against Electrolux, the manufacturer of front-loading washing machines, alleging warranty and consumer claims. Specifically, plaintiffs allege that the rubber seal on the front door of the machines retains water, allowing mildew to grow, causing stains on clothing, and creating a foul odor. The court concluded that the district court abused its discretion in assessing predominance and therefore vacated the class certification. On remand, the district court should revisit Electrolux's argument that the consumer claims do not satisfy predominance because plaintiffs cannot prove causation on a classwide basis, and the district court abused its discretion by certifying the warranty claims without first resolving preliminary questions of state law that bear on predominance. The court further concluded that plaintiffs' damages do not necessarily defeat predominance, and Electrolux's defense of misuse does not necessarily defeat predominance. Accordingly, the court vacated and remanded. View "Brown v. Electrolux Home Products, Inc." on Justia Law