Justia Class Action Opinion Summaries

Duwayne Mason appealed the district court’s grant of summary judgment in favor of Seacor, as well as the denial of Mason's motion to be recognized as a plaintiff who opted out of the class action settlement at issue in this case. Seacor owned and operated a vessel that assisted in putting out the fire after the Deepwater Horizon oil spill explosion in the Gulf of Mexico and that subsequently took part in the cleanup efforts. In response to a class action filed against it relating to damages stemming from the Deepwater Horizon incident, Seacor filed a limitation of liability action under 46 U.S.C. 30505. Mason, an employee of Seacor and a member of the crew aboard the vessel, alleged injuries sustained from his firefighting efforts. The court concluded that the district court did not abuse its discretion in failing to determine that Mason had opted out of the class action settlement through informal means. Even assuming arguendo that a reasonable indication of a desire to opt out would suffice, the court concluded that the district court did not abuse its discretion in determining that Mason’s conduct did not reasonably indicate a desire to opt out of the Medical Benefits Settlement Class. Further, the court rejected Mason's argument that the notice of the Agreement was constitutionally deficient in both delivery and content where Mason had actual notice through his counsel, which satisfies due process. Accordingly, the court affirmed the judgment. View "In Re: Deepwater Horizon" on Justia Law

This case stemmed from a settlement agreement entered into by BP and a class of parties harmed by the 2010 Deepwater Horizon oil spill. Claimants filed a “Motion for Authority to File Wetlands Claims” with the district court, invoking the district court’s supervisory authority over the interpretation and implementation of the settlement agreement. Claimants asked the district court to either determine that all seven of their claims were formally submitted in July 2012 before the six-month deadline had passed or excuse the missed six-month deadline and allow them to file claims anew. The district court denied the motion in a summary order. The court declined to deem claimants to have submitted claims on the parcels at issue in July 2012. The settlement agreement clearly designates the claim form as the manner in which claims should be submitted, and no claim forms were submitted for the two parcels at issue in July 2012, or at any time before the six-month window had closed. The court also declined to exercise any discretion it may have to excuse claimants’ failure to meet the six-month deadline. Finally, the court rejected claimants' due process claim as forfeited. Regardless, the enforcement of a properly noticed deadline generally does not effect a due process violation. Accordingly, the court affirmed the judgment. View "In re: Deepwater Horizon" on Justia Law

Plaintiff and the putative class filed suit claiming to be post-foreclosure owners of disputed oil and gas interests. After the case was removed by defendants under the Class Action Fairness Act (CAFA), 28 U.S.C. 1332(d)(2), plaintiff moved to remand to state court under the local controversy exception. The district court granted the motion and remanded. Although plaintiff has presented sufficient evidence to show that, under the narrow definition, the proposed class consists of over two-thirds Texas citizens, the court concluded that plaintiff has failed to present any evidence about those owners who purchased mineral interests post-foreclosure but have since sold or otherwise relinquished their interests. The court also concluded that plaintiff has not proven that the exception for local controversies applies because the class that the petition at the time of removal sought to have certified is not clearly limited to current owners, and there is inadequate evidence of the citizenship of the interim owners in the broader class. Accordingly, the court reversed and remanded. View "Arbuckle Mountain Ranch v. Chesapeake Energy" on Justia Law

Plaintiffs filed suit in Louisiana state court alleging personal and property damages stemming from oil pipe-cleaning operations. After the case was removed to federal court under the Class Action Fairness Act (CAFA), 28 U.S.C. 1332(d), the district court allowed jurisdictional discovery and then ordered the case remanded to state court again. The court reversed, holding that the district court erred when it found that no plaintiff satisfies CAFA’s individual amount-in-controversy requirement. The court remanded to the district court to address plaintiffs' remaining jurisdictional arguments. View "Robertson v. Chevron" on Justia Law