Justia Class Action Opinion Summaries

The case revolves around Robert Nightingale, who owed money to National Grid. The company hired two debt collectors who called Nightingale more than twice over several seven-day periods throughout 2017 and 2018. Nightingale sued National Grid and the debt collectors under the Massachusetts Consumer Protection Act, alleging that the calls invaded his privacy and caused him emotional distress. He also sought to certify a class of Massachusetts residents who had experienced similar invasions of privacy due to excessive calls from the defendants.The case was moved to federal district court, which declined to certify the class, stating that it did not meet the predominance requirement of Federal Rule of Civil Procedure 23(b)(3). The district court also granted summary judgment to the defendants, finding that Nightingale had not demonstrated a cognizable injury under the Massachusetts Consumer Protection Act.The United States Court of Appeals for the First Circuit disagreed with the district court's rulings. The appellate court held that Nightingale had alleged cognizable injuries, vacated the district court's grant of summary judgment, and also vacated the denial of class certification. The case was remanded for further proceedings consistent with the appellate court's opinion. The court found that Nightingale's receipt of unwanted calls constituted a cognizable invasion of privacy, and that his emotional distress was a cognizable injury under the Massachusetts Consumer Protection Act. The court also found that the district court had applied an incorrect legal rule in its class certification analysis. View "Nightingale v. National Grid USA Service Company Inc." on Justia Law

The case revolves around Frequency Therapeutics, a biotech startup that was developing a treatment for severe sensorineural hearing loss called "FX-322". Initial trials were positive, but subsequent testing yielded disappointing results, causing a sharp drop in Frequency's stock price. Three stockholders filed a class action lawsuit alleging violations of sections 10(b) and 20(a) of the Securities and Exchange Act of 1934, and Securities and Exchange Commission Rule 10b-5. They claimed that Frequency's CEO, David Lucchino, and its Chief Development Officer, Carl LeBel, knew of problems with the study before the results were announced, yet gave investors assurances to the contrary.The United States District Court for the District of Massachusetts dismissed the complaint, finding that the plaintiffs failed to allege sufficient facts to support a finding of scienter under the Private Securities Litigation Reform Act. The plaintiffs appealed to the United States Court of Appeals for the First Circuit.The Court of Appeals affirmed the dismissal. The court found that the plaintiffs failed to demonstrate that the defendants had made the false statements with the degree of scienter required to state a Securities and Exchange Act claim. The court noted that the complaint did not provide specific facts about when the defendants learned of the adverse events, which was a glaring omission. The court also found that the increase in stock sales by the CEO was not sufficient to establish an inference of scienter on its own. The court concluded that the plaintiffs' allegations, taken collectively, did not give rise to a strong inference of scienter. View "Quinones v. Frequency Therapeutics, Inc." on Justia Law

In this dispute, two renewable-energy generating companies, Tyngsboro Sports II Solar, LLC and 201 Oak Pembroke Solar LLC, appealed to the United States Court of Appeals for the First Circuit after their class-action lawsuit was dismissed by the District Court for the District of Massachusetts due to lack of subject-matter jurisdiction. The plaintiffs had a longstanding disagreement with defendants, utility companies National Grid USA Service Company, Inc. and Massachusetts Electric Company, over certain tax-related fees charged to them. The plaintiffs sought redress in federal court after unsuccessful petitions to state authorities.The plaintiffs argued that the district court had jurisdiction due to the case's connection to federal tax law, however, the appellate court disagreed, stating that the plaintiffs' complaint did not bring any claim that arose under federal law. The plaintiffs had brought forth four claims against National Grid, including a request for declaratory relief, a state-law claim for a breach of the covenant of good faith and fair dealing, a state-law claim for restitution and unjust enrichment, and a state-law claim for violating a statutory requirement that public utilities assess only just and reasonable charges.The appellate court affirmed the district court's dismissal of the case, finding that the plaintiffs could not establish federal-question jurisdiction simply by asserting a state-law claim to which there was a federal defense. The court noted that the state-law claims did not necessarily raise a federal issue, and to the extent that one did, the issue was not substantial. As such, the court concluded that the district court lacked jurisdiction over the claims. View "Tyngsboro Sports II Solar, LLC v. National Grid USA Service Co., Inc." on Justia Law

The First Circuit affirmed in part and reversed in part the judgment of the district court dismissing this putative action asserting various state law claims in relation to a data breach that allegedly exposed Plaintiffs' personally identifiable information (PII) and that of more than 75,000 other patients of Injured Workers Pharmacy, LLC (IWP), holding that remand was required.Plaintiffs brought a class action complaint against IWP, a home-delivery pharmacy service registered and headquartered in Massachusetts, asserting state law claims for negligence, breach of implied contract, unjust enrichment, invasion of privacy, and breach of fiduciary duty. Plaintiffs sought to certify a class of United States residents whose PII was compromised in the data breach at issue. The district court granted IWP's motion to dismiss for lack of Article III standing. The First Circuit reversed in part, holding (1) the complaint plausibly demonstrated Plaintiffs' standing to seek damages; and (2) Plaintiffs lacked standing to pursue injunctive relief because their desired injunctions would not likely redress their alleged injuries. View "Webb v. Injured Workers Pharmacy, LLC" on Justia Law

The First Circuit dismissed the appeal in the underlying putative action removed from Massachusetts state court to the federal district court concerning a motion to compel arbitration, holding that the order was not a final decision and not within an exception that would permit interlocutory review.Plaintiff brought this putative class action alleging that Defendant, a debt collector, alleging violations of Mass. Gen. Laws ch. 93A and 940 Mass. Code Regs. 7.01-.10. Defendant moved to compel arbitration in the state court, relying on an arbitration provision in the service contract between Plaintiff and the holder of the alleged debt Defendant was attempting to collect. The state court denied the motion, after which Defendant removed the case to federal court, where it filed another motion to compel arbitration. The district court treated the motion as a motion for reconsideration of the state court order denying the arbitration and then denied it. The First Circuit dismissed Defendant's appeal, holding that this was an improper interlocutory appeal. View "Powers v. Receivables Performance Management, LLC" on Justia Law

The First Circuit affirmed the judgment of the district court granting in part and denying in part Cultural Care, Inc.'s motion to dismiss this putative class action alleging violations of Plaintiffs' rights under various state and federal wage and hour laws, holding that the district court did not err.Plaintiffs sued Cultural Care, a private company that places au pairs with host families in various states, alleging that the company qualified as an "employer" under the respective states' wage and hour laws and not only failed to pay Plaintiffs what they were owed but that Cultural Care violated the Family Leave Act and other laws. Cultural Care filed a motion to dismiss, arguing, inter alia, that it was shielded from immunity under the doctrine of derivative sovereign immunity as set forth in Yearsley v. W.A. Ross Construction Co., 309 U.S. 18, 20-22 (1940). The district court dismissed the state law deceptive trade practices claims under Connecticut and Washington law for lack of standing but otherwise denied the motion. The First Circuit affirmed, holding that Cultural Care was not entitled to protection under Yearsley at this stage of the litigation. View "Posada v. Cultural Care, Inc." on Justia Law

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

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

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

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