Justia Class Action Opinion Summaries

Plaintiffs are consumers who purchased Wesson-brand cooking oil products labeled “100% Natural.” On appeal, ConAgra seeks to reverse the district court's certification of the class, arguing that the district court failed to require plaintiffs to proffer a reliable way to identify members of the certified classes. The court concluded that it has never interpreted Federal Rule of Civil Procedure 23 to require such a showing, and the court joined the Sixth, Seventh, and Eighth Circuits and declined to do so. The court explained that the language of Rule 23 neither provides nor implies that demonstrating an administratively feasible way to identify class members is a prerequisite to class certification, and the policy concerns that have motivated the Third Circuit to adopt a separately articulated requirement are already addressed by the Rule. Accordingly, the court affirmed the judgment. View "Briseno v. ConAgra Foods" on Justia Law

Plaintiff filed a putative class action against Mercer, alleging that Mercer had a common policy or practice of failing to inform domestic farm workers of the availability of H-2A work that paid $12 per hour, in violation of the Agricultural Workers’ Protection Act (AWPA), 29 U.S.C. 1831(e) and 1821(f), and the Washington Consumer Protection Act (CPA), Wash. Rev. Code 19.86.020. Plaintiffs also alleged that Mercer failed to pay its own domestic workers $12 per hour when they carried out the same tasks as foreign H-2A workers, in violation of AWPA and state wage laws.The district court certified an Inaccurate Information class and an Equal Pay subclass, corresponding to plaintiffs’ claims. In regard to the Inaccurate Information class, the court concluded that the district court did not abuse its discretion by finding common questions and in finding that common issues predominated under Federal Rule of Civil Procedure 23(b)(3). In regard to the Equal Pay subclass, the court concluded that the district court did not abuse its discretion by identifying a common question of fact concerning whether Mercer’s domestic workers were consistently paid $12 per hour for H-2A work. Finally, the court concluded that the district court did not err in finding that the typicality requirement was met in this case. Accordingly, the court affirmed the judgment. View "Ruiz Torres v. Mercer Canyons" on Justia Law

Plaintiff filed suit on his own behalf and also moved to represent 605 former and current sales associates as a class, alleging that Stoneledge requires sales associates to perform many tasks unrelated to sales. Plaintiff claimed that Stoneledge does not pay its sales associates for such work, beyond what they earn in commissions, and this policy violates California wage and hour laws. The district court granted class certification under Federal Rule of Civil Procedure 23. The court concluded that the district court permissibly concluded that plaintiff had pleaded a common injury capable of class-wide resolution; where the need for individual damages calculations does not, alone, defeat class certification, the district court permissibly ruled that individual claims did not predominate in this case; and the district court did not violate the Rules Enabling Act, 28 U.S.C. 2072(b), or abuse its discretion in certifying the class. Accordingly, the court affirmed the judgment. View "Bermudez Vaquero v. Ashley Furniture" on Justia Law

Plaintiffs, 108 individuals with property near the Boeing facility, filed suit against Boeing and Landau in state court, alleging that for several decades Boeing released toxins into the groundwater around its facility in Auburn, Washington, and that for over a decade Landau had been negligent in its investigation and remediation of the resulting pollution. Boeing removed to federal court based on diversity and the Class Action Fairness Act (CAFA), 28 U.S.C. 1332(d). The district court remanded to state court finding that there was not complete diversity and plaintiffs' action came within the single-event exception to CAFA federal jurisdiction. In this appeal, Boeing argued that plaintiffs have not demonstrated that they seek “significant relief” from Landau, the in-state defendant, and that Landau’s conduct does not form “a significant basis of the claims asserted,” as required by section 1332(d)(4)(A)(i). The court concluded that plaintiffs have adequately pled both that they are seeking “significant relief” from Landau and that Landau’s alleged conduct forms a “significant basis” for their claims. Accordingly, the court affirmed the judgment. View "Allen v. Boeing Co." on Justia Law

Florencio Pacleb filed a class action complaint against Allstate, alleging that he received unsolicited automated calls to his cell phone in violation of the Telephone Consumer Protection Act (TCPA), 47 U.S.C. 227. Allstate deposited $20,000 in full settlement of Pacleb’s individual monetary claims in an escrow account “pending entry of a final District Court order or judgment directing the escrow agent to pay the tendered funds to Pacleb, requiring Allstate to stop sending non-emergency telephone calls and short message service messages to Pacleb in the future and dismissing this action as moot.” The court affirmed the district court's order denying Allstate’s motion to dismiss for lack of subject matter jurisdiction. The court concluded that, even if the district court entered judgment affording Pacleb complete relief on his individual claims for damages and injunctive relief, mooting those claims, Pacleb would still be able to seek class certification under Pitts v. Terrible Herbst, Inc., which remains good law under Gomez v. Campbell-Ewald Co. The court also concluded that, even if Pitts were not binding, and Allstate could moot the entire action by mooting Pacleb’s individual claims for damages and injunctive relief, those individual claims are not now moot, and the court will not direct the district court to moot them by entering judgment on them before Pacleb has had a fair opportunity to move for class certification. View "Chen v. Allstate Ins. Co." on Justia Law

Appellants and appellees are two teams of named plaintiffs and their respective lawyers who disagree over the proper direction for a consumer class action settlement. In Radcliffe I, the court held that appellees created a conflict of interest by conditioning incentive awards for the class representatives on their approval of the proposed settlement agreement. On remand, appellants moved the district court to disqualify appellees’ counsel from representing the class based on that conflict. The court agreed with the district court that California does not apply a rule of automatic disqualification for conflicts of simultaneous representation in the class action context, and concluded that the district court did not abuse its discretion in determining that appellees’ counsel will adequately represent the class. Accordingly, the court affirmed the district court's denial of the qualification motion. View "Radcliffe v. Experian Info. Solutions" on Justia Law