Justia Class Action Opinion Summaries

Articles Posted in US Court of Appeals for the First Circuit
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The First Circuit vacated the approval of a class action settlement under Fed. R. Civ. P. 23(e), holding that the absence of separate settlement counsel for distinct groups of class members made too difficult a determination whether the settlement treated class members equitably.Plaintiffs sued HelloFresh, a subscription service, alleging that its so-called "win back" marketing campaign violated the Telephone Consumer Protection Act. The parties eventually arrived at a proposed settlement conditioned on court approval. The district court adopted the settlement agreement. An objector to the settlement appealed, arguing that the settlement process was unfair and led to an inequitable result. The First Circuit agreed and vacated the district court's approval, holding (1) the district court lacked the requisite basis for certifying the settlement class and approving an allocation among class members as fair, reasonable, and adequate; and (2) incentive payments to named class representatives are not prohibited so long as they fit within the bounds of Rule 23(e). View "Murray v. McDonald" on Justia Law

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The First Circuit affirmed the judgment of the district court determining that couriers who deliver goods from local restaurants and retailers are transportation workers engaged in interstate commerce such that they are exempt from the Federal Arbitration Act (FAA), 9 U.S.C. 1, holding that the district court did not err or abuse its discretion.Plaintiffs, who worked as couriers for Defendants making deliveries in the greater Boston area, filed suit in a Massachusetts state court on their own behalf and on behalf of a putative class of similarly situated couriers, alleging that Defendant had misclassified them as independent contractors rather than employees and that they were entitled to employee benefits and protections under Massachusetts law. The district court concluded that Plaintiffs were not exempt from the FAA, compelled arbitration of the dispute, and dismissed the lawsuit. The First Circuit affirmed, holding that the district court did not err in compelling arbitration and dismissing the underlying complaint. View "Immediato v. Postmates, Inc." on Justia Law

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The First Circuit affirmed the judgment of the district court dismissing all claims in this dispute between brokerage customers of Defendant, who purchased special Puerto Rico securities during a recession but before the bond market crash, holding that there was no error in the proceedings below.Plaintiffs brought a securities class action against Defendant, asserting claims under federal securities laws and Puerto Rico law. The district court entered judgment dismissing the federal law claims with prejudice and the state law claims without prejudice. The First Circuit affirmed, holding that Plaintiffs' claims that there were allegedly material omissions on the part of Defendant were not actionable. View "Ponsa-Rabell v. Santander Securities, LLC" on Justia Law

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The First Circuit affirmed the order of the district court entering summary judgment in favor of RentGrow, Inc. and dismissing Plaintiff's complaint alleging that RentGrow willfully violated the Fair Credit Reporting Act (FCRA), 15 U.S.C. 1681-1681x, holding that summary judgment was properly granted.Plaintiff commenced a civil action in the United States District Court for the District of Massachusetts, sued on her own behalf and as the representative of a putative class of similarly situated persons, alleging that Defendant was liable for both negligent and willful noncompliance with the FCRA. The district court entered summary judgment in Defendant's favor, denied class certification, and dismissed the action. The First Circuit affirmed, holding that Plaintiff did not meet her burden of adducing competent evidence sufficient to prove each and every element of her claim. View "McIntyre v. RentGrow, Inc." on Justia Law

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The First Circuit affirmed in part and vacated in part the declaratory judgment and permanent injunction issued by the district court in this class action challenging the bond procedures used to detain noncitizen during the pendency of removal proceedings under 8 U.S.C. 1226(a), the discretionary immigration detention provision, holding that the district court lacked jurisdiction to issue injunctive relief in favor of the class.Specifically, the First Circuit held (1) the district court did not err in declaring that noncitizens "detained pursuant to 8 U.S.C. 1226(a) are entitled to receive a bond hearing at which the government must prove the alien is either dangerous by clear and convincing evidence or a risk of flight by a preponderance of the evidence"; (2) the classwide injunction in this case unlawfully enjoined or restrained the operation of section 1226(a); and (3) the remaining portion of the district court's declaration was advisory. View "Pereira Brito v. Garland" on Justia Law

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The First Circuit affirmed the judgment of the district court granting two summary judgment motions in favor of Defendants in this class action lawsuit, holding that Defendants' actions in this case could not support a claim under the Racketeer Influenced and Corrupt Organizations Act (RICO).In granting the two summary judgment motions at issue, one filed on behalf of all Defendants and on filed behalf of certain Defendants, the district court adopted the findings of law of the Court of Appeals of Puerto Rico in Collazo Burgos v. La Asociación de Suscripción Conjunta del Seguro de Responsabilidad Obligatorio, No. K AC2010-0179, 2017 WL 6884428 (P.R. Cir. Nov. 30, 2017). The court further held that Defendants' actions were required under Puerto Rico law and thus could not support a RICO claim. The First Circuit affirmed, holding that the district court did err under the Erie doctrine in adopting the reasoning of the court of appeals in Collazo Burgos. View "Torres-Ronda v. Nationwide Mutual Insurance Co." on Justia Law

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The First Circuit affirmed the rulings of the district court denying the Commission of the New Hampshire Department of Health and Human Services' motion to dismiss Plaintiffs' complaints against her, holding that Plaintiffs' allegations of error were without merit.Plaintiffs were (1) a class of individuals who claimed to have been held against their will without due process on the basis of a certification of their need for emergency mental health treatment, and (2) a group of hospitals who claimed to have been forced to retain persons certified to be in need of such treatment. The Commissioner moved to dismiss the claims based on Eleventh Amendment immunity and Plaintiffs' asserted lack of standing. The district court denied the motion to dismiss. The First Circuit affirmed, holding that there was no merit to the Commissioner's challenges to the district court's standing and Eleventh Amendment immunity rulings. View "Doe v. Shibinette" on Justia Law

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The First Circuit affirmed the ruling of the district court that there was no per se constitutional entitlement to a bond hearing after six months of detention and otherwise vacated the district court's declaratory and injunctive relief, holding that it was advisory.Petitioners brought this class action on behalf of noncitizen detainees held without possibility of release pending the completion of their removal proceedings. On remand, Petitioners alleged that mandatory detention of the class members under 8 U.S.C. 1226(c) for more than six months violated the Fifth Amendment Due Process Clause or the Eighth Amendment excessive Bail Clause. The district court ruled that there was no per se constitutional entitlement to a bond hearing after six months of detention but that the length of time that might constitutionally pass without a bond hearing turned on each noncitizen's individual circumstances. The court then issued declaratory and injunctive relief in favor of all class members. The First Circuit held (1) the district court properly rejected the claim that persons detained for six months under section 1226(c) are automatically entitled to a bond hearing; and (2) the district court improperly granted binding equitable relief. View "Reid v. Donelan" on Justia Law

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The First Circuit dismissed this appeal from the United States District Court for the District of Massachusetts denying Appellant's first preliminary injunction motion, holding that this Court had no appellate jurisdiction.Appellant filed a class action complaint in the Massachusetts district court under the Class Action Fairness Act, 28 U.S.C. 1332(d)(2) alleging that Uber Technologies, Inc. misclassified him and other drivers as independent contractors instead of employees. Appellant filed a motion for a preliminary injunction requiring Uber to alter its classification. The district court denied the motion. The First Circuit affirmed, holding that, due to the procedural posture of this case, this Court did not have jurisdiction to hear the appeal. View "Capriole v. Uber Technologies, Inc." on Justia Law

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The First Circuit issued this narrow opinion in response to the Commonwealth of Massachusetts's appeal from the district court's denial of its "Motion Regarding Substantial Compliance and To Terminate Monitoring and Court Supervision" and reversed, holding that the district court's analysis was flawed.The underlying suit was long-running class-action litigation concerning the Commonwealth of Massachusetts's compliance with federal statutory requirements for provision of services to a plaintiff class of Medicaid-eligible children with serious emotional disturbances. The district court found the Commonwealth liable for violating Medicaid provisions as to "reasonable promptness" and "early and periodic screening, diagnosis, and treatment" services. The court then issued remedial orders and a court monitor was appointed. Later the Commonwealth filed the motion at issue. Plaintiffs agreed that the court could terminate monitoring and reporting over the portions of the judgment the Commonwealth was in substantial compliance with. The district court denied the motion in its entirety. The First Circuit reversed, holding that the district court's analysis was flawed from the outset. View "Rosie D. v. Baker" on Justia Law