Justia Class Action Opinion Summaries

The Eighth Circuit reversed the district court's order certifying a class under Federal Rules of Civil Procedure 23(b)(2) and (b)(3), holding that the district court abused is discretion in finding that plaintiffs met the cohesiveness, and predominance and superiority requirements. In this case, plaintiff and other current and former employees of Union Pacific moved to certify a class action for a claim under the Americans with Disabilities Act (ADA). The district court granted a hybrid class defined to include all employees who have been or will be subject to a fitness-for-duty evaluation because of a reportable health event from September 18, 2014 until the end of the case.The court held that the individualized inquiries in this case cannot be addressed in a manner consistent with Rule 23; determining whether the policy is job related and consistent with business necessity requires answering many individual questions; both the text of the ADA and the record evidence demonstrate that the district court would be required to consider the unique circumstances of each position in question to determine whether the policy is unlawfully discriminatory; and thus these individualized questions defeated both predominance and cohesiveness. View "Harris v. Union Pacific Railroad Co." on Justia Law

Plaintiffs filed a putative class action alleging that defendants deceived plaintiffs into believing their products were approved by the FDA. After the district court remanded the case back to state court, the Eighth Circuit granted defendants' petition for review under 28 U.S.C. 1453(c)(1), limiting review to the issue of federal question jurisdiction.The court held that federal question jurisdiction exists in this case, because plaintiffs rely explicitly on federal law throughout their pleadings and their prayer for relief invokes federal jurisdiction where it seeks injunctive and declaratory relief that necessarily requires the interpretation and application of federal law, including the Food Drug and Cosmetic Act. Therefore, based on the allegations in the complaint and relief sought, the court found that a federal issue surrounding the state law claims is necessarily raised, actually disputed, substantial, and capable of resolution in federal court without disrupting the federal-state balance approved by Congress. Accordingly, the court vacated and remanded for further proceedings. View "Wullschleger v. Royal Canin U.S.A., Inc." on Justia Law

The Eighth Circuit reversed the district court's order certifying a nationwide class of plaintiffs in a case involving allegedly deceptive advertising practices. The action arose out of allegedly deceptive advertising associated with RIDGID brand vacuums. The district concluded that all class members' claims would be governed by Missouri law and thus determined class resolution was appropriate.The court held that the claims of non-Missouri residents did not relate to “trade or commerce . . . in or from the state of Missouri” and the Missouri Merchandising Practices Act could not be applied to them. The court also held that the district court should have conducted separate choice of law analyses for the breach of warranty and unjust enrichment claims. Accordingly, the court remanded for further proceedings. View "Hale v. Emerson Electric Co." on Justia Law

Plaintiffs filed a class action in state court against Massage Envy, alleging that the company violated the Missouri Merchandising Practices Act (MMPA) when advertisements for its one hour massage session failed to disclose that the session included ten minutes to undress, dress, and consult with the therapist. Massage Envy removed the case to district court under the Class Action Fairness Act.The Eighth Circuit held that the district court misapplied controlling Supreme Court and Eighth Circuit CAFA precedents. The court held that the district court erred when it evaluated the MMPA violations alleged in plaintiffs' second amended petition and remanded the class action to state court because "it is more likely that a reasonable fact finder would not award several million dollars in punitive damages." In this case, the district court's consideration went to the merits of plaintiffs' claims. The court held that plaintiffs' allegation that they were entitled to punitive damages in an unstated amount raised the amount in controversy to more than $5 million, whether or not they ultimately prove they were entitled to the punitive damages they claimed. Finally, the court also held that when Massage Envy investigated and filed a notice of removal based on the results of its own amount-in-controversy investigation, the notice was not untimely. Therefore, the court granted the petition for permission to appeal, reversed the July 2019 order of remand, denied plaintiffs' motion for remand, and remanded for further proceedings. View "Pirozzi v. Massage Envy Franchising" on Justia Law

Plaintiff filed a class action in state court against Walgreens and others, claiming that the Walgreens Balance Rewards program violated Arkansas's statutory prohibition on price discrimination in the sale of manufactured products. After defendants removed to federal court under the Class Action Fairness Act of 2005 (CAFA), the district court denied remand and granted defendants' motion to dismiss.The Eighth Circuit affirmed, holding that the district court did not err by finding that the district managers were not significant defendants under CAFA, and in concluding that they had been fraudulently joined in an attempt to defeat diversity jurisdiction. In light of the court's determination that the district managers' conduct did not form a significant basis for plaintiff's claim, the court held that plaintiff failed to meet his burden of establishing that the local controversy exception to CAFA jurisdiction applies. The court rejected plaintiff's argument that the district court was without jurisdiction to decide the merits of his case because he did not have Article III standing. Finally, the court rejected plaintiff's claim that the district court erred in dismissing his complaint with prejudice. View "Atwood v. Peterson" on Justia Law

Objector was a member of a California class action against Monsanto that alleged that the company used misleading labeling on its Roundup concentrate herbicide. After certification of the class, class counsel filed this action on behalf of a putative class of consumers from the other 49 states. Objector objected to certification of the nationwide class and to the fairness of the settlement on several grounds. The Eighth Circuit affirmed the district court's overruling of the objection and grant of final approval. The court held that the class members were adequately represented and that the settlement was reasonable, fair, and adequate. View "Rawa v. Migliaccio" on Justia Law

Plaintiff filed suit against the police chief, the city, and other public officials, alleging violations of the Driver's Privacy Protection Act (DPPA). After the police chief admitted liability for six violations of the Act, the jury awarded plaintiff punitive damages. The district court ruled that plaintiff failed to present sufficient evidence that the city was directly liable for the violations, but authorized the jury's finding that the city was vicariously liable for the police chief's actions.The Eighth Circuit affirmed and held that the district court did not abuse its discretion by ruling that plaintiff's proposed class failed to satisfy the numerosity requirement of Federal Rule of Civil Procedure 23(a) and the predominance requirement of Rule 23(b)(3); the district court properly refused to entertain direct liability against the city where the police chief acted for personal reasons, not under the auspices of official policymaking authority, and thus his actions did not represent a policy of the city; the district court correctly construed the civil action provisions of the Act to incorporate background tort-related rules of vicarious liability; the district court did not abuse its discretion in excluding certain evidence at trial; and the district court did not err in declining to award requested costs. The court rejected plaintiff's remaining claims and denied the city's motion to strike portions of plaintiff's appendix and brief. View "Orduno v. Pietrzak" on Justia Law

Four groups of prospective intervenors challenged the district court's denials of their motions to intervene in a class action lawsuit by named plaintiff Connie Jean Smith against SEECO, as well as the district court's procedures for opting-out from the class. The Eighth Circuit affirmed the district court's ruling that Charter Land's motion to intervene was untimely because it merely repeated arguments already advanced by other attempted intervenors after the class was unsuccessful. The court dismissed the remaining appeals for lack of jurisdiction because the appeals were not filed within 30 days of the district court's order denying intervention. View "Smith v. Arnett" on Justia Law

Former employees of Honeywell, who retired before age 65 during the terms of Honeywell's 2007 and 2010 collective bargaining agreements (CBAs), filed a class action alleging that Honeywell's announced plan to terminate early retiree healthcare benefits at the end of 2017 breached the CBAs and violated the Employee Retirement Income Security Act of 1974 (ERISA), because those healthcare benefits vested when each class member retired.The Eighth Circuit agreed with the Sixth Circuit and held that the Supreme Court's decision in CNH Indus. N.V. v. Reese, 138 S. Ct. 761 (2018), was controlling in this case. Under Reese, the court held that plaintiffs' retiree healthcare benefits were not vested as a matter of law. Therefore, the court reversed and remanded for further proceedings. View "Pacheco v. Honeywell International Inc." on Justia Law

After plaintiff obtained a home equity loan from Countrywide, he filed a pro se complaint alleging five causes of action against Bank of America, the company that acquired Countrywide. The Eighth Circuit affirmed the district court's dismissal of two claims based on Bank of America's failure to honor plaintiff's alleged early payoff right. In this case, plaintiff's claims were barred by the doctrine of res judicata because he had been a member of a global class action settlement that included a broad release of claims by all class members. The court also held that the district court did not abuse its discretion by promptly setting the remaining claims for trial. The court explained that, at minimum, Bank of America failed to establish that the statute of frauds barred these claims as a matter of law on the record. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Calon v. Bank of America Corp." on Justia Law