Justia Class Action Opinion Summaries

The case involves the city of Grants Pass, Oregon, and its laws restricting public camping. The city's laws prohibit activities such as camping on public property or parking overnight in the city’s parks. Violations can result in fines and, in the case of multiple violations, imprisonment. A group of homeless individuals filed a class action lawsuit against the city, arguing that these ordinances violated the Eighth Amendment's prohibition against cruel and unusual punishment. The district court agreed with the plaintiffs, citing a previous Ninth Circuit decision, Martin v. Boise, which held that cities cannot enforce public camping ordinances against homeless individuals when the number of homeless individuals exceeds the number of available shelter beds.The Ninth Circuit affirmed the district court's decision, leading to the city's appeal to the Supreme Court. The Supreme Court reversed the Ninth Circuit's decision, holding that the enforcement of laws regulating camping on public property does not constitute "cruel and unusual punishment" prohibited by the Eighth Amendment. The Court reasoned that the Eighth Amendment focuses on the punishment a government may impose after a criminal conviction, not on whether a government may criminalize particular behavior in the first place. The Court also noted that the punishments imposed by the city of Grants Pass, such as fines and temporary bans from public parks, did not qualify as cruel and unusual under the Eighth Amendment. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "City of Grants Pass v. Johnson" on Justia Law

The case revolves around a dispute between Alex Cantero, Saul Hymes, Ilana Harwayne-Gidansky, and others (the plaintiffs) and Bank of America. The plaintiffs had obtained home mortgage loans from Bank of America, which required them to make monthly deposits into escrow accounts. These accounts were used by the bank to pay the borrowers' property taxes and insurance premiums. Under New York law, banks are required to pay borrowers interest on the balance of such escrow accounts. However, Bank of America did not pay interest on the money in the plaintiffs' escrow accounts, arguing that the New York law was preempted by the National Bank Act. The plaintiffs filed class-action suits against Bank of America, alleging that the bank violated New York law by failing to pay them interest on the balances in their escrow accounts.The U.S. District Court for the Eastern District of New York ruled in favor of the plaintiffs, agreeing that New York law required Bank of America to pay interest on the escrow account balances. The court concluded that nothing in the National Bank Act or other federal law preempted the New York law. However, the U.S. Court of Appeals for the Second Circuit reversed this decision, holding that the New York interest-on-escrow law was preempted as applied to national banks. The Court of Appeals argued that federal law preempts any state law that attempts to exercise control over a federally granted banking power, regardless of the magnitude of its effects.The Supreme Court of the United States, in reviewing the case, focused on the standard for determining when state laws that regulate national banks are preempted. The Court noted that the Dodd-Frank Act of 2010 expressly incorporated the standard articulated in Barnett Bank of Marion County, N. A. v. Nelson, which asks whether a state law "prevents or significantly interferes with the exercise by the national bank of its powers." The Supreme Court found that the Court of Appeals did not apply this standard in a manner consistent with Dodd-Frank and Barnett Bank. Therefore, the Supreme Court vacated the judgment of the Court of Appeals and remanded the case for further proceedings consistent with its opinion. View "Cantero v. Bank of America, N. A." on Justia Law

The case involves a dispute between Coinbase, Inc., a cryptocurrency exchange platform, and its users. The users had agreed to two contracts with Coinbase. The first contract, the User Agreement, contained an arbitration provision stating that an arbitrator must decide all disputes, including whether a disagreement is arbitrable. The second contract, the Official Rules for a promotional sweepstakes, contained a forum selection clause stating that California courts have sole jurisdiction over any controversies regarding the promotion. The users filed a class action in the U.S. District Court for the Northern District of California, alleging that the sweepstakes violated various California laws. Coinbase moved to compel arbitration based on the User Agreement’s arbitration provision. The District Court denied the motion, ruling that the Official Rules’ forum selection clause controlled the dispute. The Ninth Circuit affirmed this decision.The Supreme Court of the United States affirmed the Ninth Circuit's decision. The Court held that when parties have agreed to two contracts—one sending arbitrability disputes to arbitration, and the other either explicitly or implicitly sending arbitrability disputes to the courts—a court must decide which contract governs. The Court rejected Coinbase's arguments that the Ninth Circuit should have applied the severability principle and that the Ninth Circuit erroneously held that the Official Rules’ forum selection clause superseded the User Agreement’s arbitration provision. The Court also dismissed Coinbase's concern that its ruling would invite chaos by facilitating challenges to delegation clauses. The Court concluded that a court, not an arbitrator, must decide whether the parties’ first agreement was superseded by their second. View "Coinbase v. Suski" on Justia Law

California’s Labor Code Private Attorneys General Act (PAGA) authorizes any “aggrieved employee” to initiate an action against a former employer on behalf of himself and other current or former employees to obtain civil penalties that previously could have been recovered only by California’s Labor and Workforce Development Agency. California precedent holds that a PAGA suit is a “representative action” in which the plaintiff sues as an “agent or proxy” of the state. Moriana filed a PAGA action against her former employer, Viking, alleging multiple violations with respect to herself and other employees. Moriana’s employment contract contained a mandatory arbitration agreement with a “Class Action Waiver,” providing that the parties could not bring any class, collective, or representative action under PAGA, and a severability clause. California courts denied Viking’s motion to compel arbitration.The Supreme Court reversed. The Federal Arbitration Act, 9 U.S.C. 1 (FAA), preempts California precedent that precludes division of PAGA actions into individual and non-individual claims through an agreement to arbitrate. Viking was entitled to compel arbitration of Moriana’s individual claim. Moriana would then lack standing to maintain her non-individual claims in court.A PAGA action asserting multiple violations under California’s Labor Code affecting a range of different employees does not constitute “a single claim.” Nothing in the FAA establishes a categorical rule mandating enforcement of waivers of standing to assert claims on behalf of absent principals. PAGA’s built-in mechanism of claim joinder is in conflict with the FAA. State law cannot condition the enforceability of an agreement to arbitrate on the availability of a procedural mechanism that would permit a party to expand the scope of the anticipated arbitration by introducing claims that the parties did not jointly agree to arbitrate. View "Viking River Cruises, Inc. v. Moriana" on Justia Law

When a business opted into its Name Screen Alert service, TransUnion would conduct its ordinary credit check of the consumer and would also use third-party software to compare the consumer’s name against the Treasury Department’s Office of Foreign Assets Control's list of terrorists, drug traffickers, and other serious criminals. If the consumer’s first and last name matched the first and last name of an individual on that list, TransUnion would note on the credit report that the consumer’s name was a “potential match.”A class of 8,185 individuals with such alerts in their credit files sued TransUnion under the Fair Credit Reporting Act, 15 U.S.C. 1681. for failing to use reasonable procedures to ensure the accuracy of their credit files. The parties stipulated that only 1,853 class members had their misleading credit reports containing alerts provided to third parties during the seven-month period specified in the class definition. The Ninth Circuit affirmed a jury verdict, awarding each class member statutory and punitive damages.The Supreme Court reversed. Only plaintiffs concretely harmed by a defendant’s statutory violation have Article III standing to seek damages in federal court. An injury-in-law is not an injury-in-fact. The asserted harm must have a close relationship to harm traditionally recognized as providing a basis for a lawsuit. Physical or monetary harms and various intangible harms—like reputational harms--qualify as concrete injuries under Article III; 1,853 class members suffered harm with a “close relationship” to the harm associated with the tort of defamation. The credit files of the remaining 6,332 class members contained misleading alerts, but TransUnion did not provide that information to potential creditors. The mere existence of inaccurate information, absent dissemination, traditionally has not provided the basis for a lawsuit. Exposure to the risk that the misleading information would be disseminated in the future, without more, cannot qualify as concrete harm in a suit for damages. View "TransUnion LLC v. Ramirez" on Justia Law

Plaintiffs brought class action claims against Google, claiming violations of the Stored Communications Act; they alleged that when an Internet user conducted a Google search and clicked on a hyperlink listed on the search results, Google transmitted information (referrer header) including the terms of the search to the server that hosted the selected webpage. The Act prohibits “a person or entity providing an electronic communication service to the public” from “knowingly divulg[ing] to any person or entity the contents of a communication while in electronic storage by that service” and creates a private right of action. The district court denied a motion to dismiss, citing a Ninth Circuit holding (Edwards) that an Article III injury exists whenever a statute gives an individual a statutory cause of action and the plaintiff claims that the defendant violated the statute.The parties negotiated a classwide settlement that allowed the continued transmission of referrer headers but required Google to include disclosures on three of its webpages and to pay $8.5 million. None of those funds would be distributed to absent class members; most of the money would be distributed to cy pres recipients. In a class action, cy pres refers to distributing settlement funds not amenable to individual claims or meaningful pro rata distribution to nonprofit organizations whose work indirectly benefits class members. The balance would be used for administrative costs, given to the named plaintiffs, and awarded as attorney’s fees. In the meantime, the Supreme Court (Spokeo) held that “Article III standing requires a concrete injury even in the context of a statutory violation,” rejecting the "Edwards" premise. The Ninth Circuit affirmed approval of the settlement without addressing Spokeo.The Supreme Court vacated. Although the Court granted certiorari to decide whether a class action settlement that provides a cy pres award but no direct relief to class members is “fair, reasonable, and adequate,” Fed. Rule Civ. Proc. 23(e)(2), the Court concluded that there is a substantial open question about whether any named plaintiff had standing. A court cannot approve a proposed class settlement if it lacks jurisdiction over the dispute, and federal courts lack jurisdiction if no named plaintiff has standing. When the district court ruled on the motion to dismiss, it relied on precedent that was subsequently abrogated in Spokeo. View "Frank v. Gaos" on Justia Law

Lambert filed a class action, alleging that Nutraceutical’s marketing of a dietary supplement violated California consumer-protection law. On February 20, 2015, the district court decertified the class. Under Federal Rule of Civil Procedure 23(f), Lambert had 14 days to ask for permission to appeal the order. Instead, he moved for reconsideration more than 14 days later, on March 12. The district court denied the motion on June 24. Fourteen days later, Lambert petitioned the Ninth Circuit for permission to appeal the decertification order. The Ninth Circuit held that Rule 23(f)’s deadline should be tolled because Lambert had “acted diligently” and reversed the decertification order. A unanimous Supreme Court reversed. Rule 23(f), “a nonjurisdictional claim-processing rule,” is not subject to equitable tolling. Whether a rule precludes equitable tolling turns not on its jurisdictional character but on whether its text leaves room for such flexibility. Rule 26(b), which generally authorizes extensions of time, states that a court of appeals “may not extend the time to file . . . a petition for permission to appeal.” The Rules express a clear intent to compel rigorous enforcement of Rule 23(f)’s deadline, even where good cause for equitable tolling might otherwise exist. A timely motion for reconsideration would affect the when the 14-day limit begins to run, not the availability of tolling. View "Nutraceutical Corp. v. Lambert" on Justia Law

Dean, an Agritech shareholder, filed a class-action complaint on February 11, 2011, alleging violations of the Securities Exchange Act of 1934, which has a two-year statute of limitations and a five-year statute of repose, 28 U.S.C. 1658(b). The accrual date for the limitation period is February 3, 2011 and for the repose period, November 12, 2009. In May 2012, the district court denied class certification; the action settled and the suit was dismissed. On October 4, 2012, Dean’s counsel filed a new, timely, complaint (Smyth), with a new set of plaintiffs. Eight shareholders sought lead-plaintiff appointment but the district court again denied class certification. The Smyth plaintiffs settled their individual claims and dismissed their suit. Resh, who did not seek lead-plaintiff status in the earlier actions, filed a class action in 2014 after the statute of limitations expired. The Supreme Court’s 1974 “American Pipe” decision established that the timely filing of a class action tolls the statute of limitations for all persons encompassed by the class complaint and that members of a class that fails to gain certification can timely intervene as individual plaintiffs in the still-pending action and applies to putative class members who, after denial of class certification, “prefer to bring an individual suit rather than intervene.” The Supreme Court reversed the Ninth Circuit and reinstated dismissal of Resh's suit. Upon denial of class certification, a putative class member may not, in lieu of promptly joining an existing suit or filing an individual action, commence a new class action after the limitations period. The “efficiency and economy of litigation” that support tolling of individual claims do not support maintenance of untimely successive class actions. View "China Agritech, Inc. v. Resh" on Justia Law

The Southern District of California adopted a districtwide policy permitting the use of full restraints—handcuffs connected to a waist chain, with legs shackled—on most in-custody defendants produced in court for non-jury proceedings by the U.S. Marshals Service. Before the Ninth Circuit could issue a decision on a challenge to the policy, the underlying criminal cases ended. That court—viewing the case as a “functional class action” seeking “class-like relief,” held that the case was not moot and the policy was unconstitutional. A unanimous Supreme Court vacated, finding the case moot. The federal judiciary may adjudicate only “actual and concrete disputes, the resolutions of which have direct consequences on the parties involved.”. Such a dispute “must be extant at all stages of review, not merely at the time the complaint is filed.” Precedent does not support a freestanding exception to mootness outside the Rule 23 class action context. The Federal Rules of Criminal Procedure establish for criminal cases no vehicle comparable to the civil class action, and the Supreme Court has never permitted criminal defendants to band together to seek prospective relief in their individual cases on behalf of a class. The “exception to the mootness doctrine for a controversy that is capable of repetition, yet evading review” does not apply, based only the possibility that some of the parties again will be prosecuted for violating valid criminal laws. View "United States v. Sanchez-Gomez" on Justia Law

In 2007-2008, Lehman Brothers raised capital through public securities offerings. Petitioner, the largest public pension fund in the country, purchased some of those securities. A 2008 putative class action claimed that financial firms were liable under the Securities Act of 1933, 15 U.S.C. 77k(a), for their participation as underwriters in the transactions, alleging that certain registration statements for Lehman’s offerings included material misstatements or omissions. More than three years after the relevant offerings, petitioner filed a separate complaint with the same allegations. A proposed settlement was reached in the putative class action, but petitioner opted out. The Second Circuit affirmed dismissal of the individual suit, citing the three-year bar in Section 13 of the Act. The Supreme Court affirmed. Section 13’s first sentence states a one-year limitations period; the three-year time limit is a statute of repose, not subject to equitable tolling. Its instruction that “[i]n no event” shall an action be brought more than three years after the relevant securities offering admits of no exception. The statute runs from the defendant’s last culpable act (the securities offering), not from the accrual of the claim (the plaintiff’s discovery of the defect). Tolling is permissible only where there is a particular indication that the legislature did not intend the statute to provide complete repose but instead anticipated the extension of the statutory period under certain circumstances. The timely filing of a class-action complaint does not fulfill the purposes of a statutory time limit for later-filed suits by individual class members. View "California Public Employees’ Retirement System v. ANZ Securities, Inc." on Justia Law