Justia Class Action Opinion Summaries

N.S. was arrested for robbery and destruction of property and was released on his own recognizance by a Magistrate Judge. However, before he could leave the courthouse, U.S. Marshals detained him based on an ICE detainer. N.S. filed a class complaint alleging that the Marshals acted beyond their statutory authority by making a civil immigration arrest, violating the Administrative Procedure Act.The United States District Court for the District of Columbia certified the proposed class and granted N.S.'s request for a permanent injunction, prohibiting Marshal Dixon and his agents from arresting and detaining criminal defendants in the Superior Court for suspected civil immigration violations. The court held that the Marshals were not authorized to make civil immigration arrests as they had not undergone the required training. The court also found that the 2002 Order delegating authority to the Marshals lacked sufficient legal support.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Marshals were not authorized to make civil immigration arrests due to the lack of required training. However, the court found that the class-wide injunction issued by the district court was barred by 8 U.S.C. § 1252(f)(1), which prohibits lower courts from enjoining the operation of certain immigration provisions. The court vacated the injunction and remanded the case to the district court to reconsider the appropriate remedy. View "N.S. v. Dixon" on Justia Law

In 2018, South Carolina excluded Planned Parenthood from its Medicaid program, citing state law prohibiting public funds for abortion. Planned Parenthood and patient Julie Edwards sued, claiming the exclusion violated the Medicaid any-qualified-provider provision, which allows Medicaid beneficiaries to obtain services from any qualified provider. Edwards preferred Planned Parenthood for gynecological care but needed Medicaid coverage. They filed a class action under 42 U.S.C. §1983 to enforce rights under the federal Medicaid statutes.The district court granted summary judgment for the plaintiffs and enjoined the exclusion. The Fourth Circuit affirmed. The Supreme Court granted certiorari, vacated, and remanded the case in light of Health and Hospital Corporation of Marion Cty. v. Talevski, which addressed whether another spending-power statute created §1983-enforceable rights. On remand, the Fourth Circuit reaffirmed its decision.The Supreme Court of the United States held that Section 1396a(a)(23)(A) does not clearly and unambiguously confer individual rights enforceable under §1983. The Court emphasized that spending-power statutes rarely create enforceable rights and that the any-qualified-provider provision lacks the clear rights-creating language necessary to support a §1983 action. The Court reversed the Fourth Circuit's decision and remanded the case for further proceedings consistent with this opinion. View "Medina v. Planned Parenthood South Atlantic" on Justia Law

A data breach occurred at Wawa convenience stores, affecting customers' payment information. Wawa discovered the breach in December 2019 and contained it within days. The breach led to a class action lawsuit filed in the U.S. District Court for the Eastern District of Pennsylvania, consolidating 15 actions into three tracks: financial institution, employee, and consumer. The consumer track, which is the focus of this case, alleged negligence, breach of implied contract, and violations of state consumer protection laws, seeking both damages and injunctive relief.The District Court preliminarily approved a settlement that included compensation through Wawa gift cards and cash for out-of-pocket losses, as well as injunctive relief to improve Wawa's data security. Class member Theodore Frank objected, arguing that the settlement's attorney's fees were excessive and that the settlement included a clear sailing agreement and a fee reversion clause. The District Court approved the settlement and the attorney's fees, but Frank appealed.The United States Court of Appeals for the Third Circuit vacated the fee award and remanded the case, instructing the District Court to scrutinize the reasonableness of the attorney's fees and the presence of any side agreements. On remand, the District Court found no clear sailing agreement or collusion and determined that the fee reversion was unintentional. The court reaffirmed the attorney's fee award based on the funds made available to the class, considering the benefits provided, including the injunctive relief.The Third Circuit reviewed the District Court's findings and affirmed the judgment, holding that the attorney's fee award was reasonable and that the settlement process was free of collusion or improper side agreements. The court emphasized the meaningful benefits provided to the class members and the appropriateness of the fee award based on the amount made available rather than the amount claimed. View "In re: Wawa, Inc. Data Security Litigation" on Justia Law

Joanne Allison, a former registered nurse, filed a class action lawsuit against her former employer, Dignity Health, alleging unpaid work, meal period, and rest break violations. She sought class certification for registered nurses at three Dignity hospitals since June 1, 2014. Allison's expert claimed that time records showed over 70% of shifts had noncompliant meal periods. She also argued that work-issued communication devices interrupted rest breaks, violating labor laws.The trial court initially granted partial class certification, finding common questions suitable for class treatment, including the legality of Dignity's premium request requirement and the impact of communication devices on breaks. However, Dignity later moved to decertify the class, citing post-certification discovery that revealed significant variations in nurses' experiences and practices, undermining the manageability of class-wide adjudication.The California Court of Appeal, First Appellate District, reviewed the case. The court found that the trial court did not abuse its discretion in considering new evidence from post-certification depositions, which showed varied reasons for noncompliant meal periods, such as personal preferences and mistakes. The court also upheld the trial court's decision to disregard the Steiner survey due to methodological flaws and potential biases, which rendered it unreliable for proving class-wide liability.The appellate court affirmed the trial court's decertification order, agreeing that individualized inquiries predominated over common questions, making class treatment unmanageable. The court also noted that the evidence did not support a uniform practice of requiring nurses to carry work phones during breaks, further complicating the rest break claims. Thus, the order decertifying the class was affirmed. View "Allison v. Dignity Health" on Justia Law

Two corrections officers, Nicole McDaniel and Matthew Davis, filed a class-action lawsuit against the Wisconsin Department of Corrections (DOC), seeking compensation for time spent in correctional facilities before and after their shifts. They argued that these pre- and post-shift activities, such as passing through security and obtaining equipment, are integral to their principal activities and should be compensable under Wisconsin regulations. The DOC employs approximately 5,000 corrections officers across 37 prisons, all of whom are required to complete these activities, though the specifics and duration may vary.The Milwaukee County Circuit Court certified the class, finding that the plaintiffs made a plausible argument for compensation and met the statutory requirements for class certification, including commonality, typicality, predominance, and superiority. However, the Wisconsin Court of Appeals reversed the decision, arguing that the class would lose on the merits because the pre- and post-shift activities were not compensable, thus failing the commonality and typicality requirements.The Wisconsin Supreme Court reviewed the case and clarified that a court should not consider the merits of the underlying claim when assessing class-certification requirements. The court determined that the circuit court did not erroneously exercise its discretion in certifying the class. The Supreme Court held that the common question of whether the pre- and post-shift activities are compensable predominates over individual issues and that a class action is a superior method for resolving the controversy. Consequently, the Supreme Court reversed the Court of Appeals' decision and remanded the case to the circuit court for further proceedings. View "McDaniel v. Department of Corrections" on Justia Law

A plaintiff filed a putative class action against a dietary supplement company, alleging that the supplement Hydro BCAA was mislabeled. The plaintiff claimed that preliminary testing showed the supplement contained more carbohydrates and calories than listed on its FDA-prescribed label. The plaintiff tested the supplement using FDA methods but did not follow the FDA’s twelve-sample sampling process.The United States District Court for the Southern District of California dismissed the complaint, holding that the Food, Drug, and Cosmetic Act preempted the claims because the plaintiff did not plead that he tested the supplement according to the FDA’s sampling process. The district court noted a divide among district courts on whether plaintiffs must plead compliance with the FDA’s testing methods and sampling processes to avoid preemption.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the plaintiff’s complaint allowed a reasonable inference that the supplement was misbranded under the Act, even without allegations of compliance with the FDA’s sampling process. The court found that the plaintiff’s preliminary testing of one sample, which showed significant discrepancies in carbohydrate and calorie content, was sufficient to survive a motion to dismiss. The court emphasized that plaintiffs are not required to perform the FDA’s sampling process at the pleading stage to avoid preemption.The Ninth Circuit reversed the district court’s dismissal, allowing the plaintiff’s state-law claims to proceed. The court concluded that the plaintiff’s allegations were sufficient to avoid preemption and stated a plausible claim that the supplement was mislabeled under the Act. View "SCHEIBE V. PROSUPPS USA, LLC" on Justia Law

McKesson Corporation sent unsolicited fax advertisements to medical practices, including McLaughlin Chiropractic Associates, in 2009 and 2010. McLaughlin sued McKesson in 2014 in the U.S. District Court for the Northern District of California, alleging violations of the Telephone Consumer Protection Act (TCPA) for sending unsolicited faxes without the required opt-out notices. McLaughlin sought damages and an injunction and aimed to represent a class of fax recipients who received the advertisements on traditional fax machines or through online fax services. The District Court certified the class without distinguishing between the two methods of receipt.During the lawsuit, the Federal Communications Commission (FCC) issued the Amerifactors order, which interpreted "telephone facsimile machine" in the TCPA to exclude online fax services. The District Court, following Ninth Circuit precedent, deemed the Amerifactors order binding and granted summary judgment to McKesson for claims involving online fax services. The court then decertified the class, leaving McLaughlin with claims for only 12 faxes received on a traditional machine and damages of $6,000. The Ninth Circuit affirmed the District Court's decision.The Supreme Court of the United States reviewed the case and held that the Hobbs Act does not bind district courts in civil enforcement proceedings to an agency’s interpretation of a statute. District courts must independently determine the law’s meaning under ordinary principles of statutory interpretation while affording appropriate respect to the agency’s interpretation. The Court reversed the Ninth Circuit's decision and remanded the case for further proceedings consistent with this opinion. View "McLaughlin Chiropractic Associates, Inc. v. McKesson Corp." on Justia Law

Former students of the University of Montana filed a class action lawsuit against the university, alleging mishandling of student loan reimbursement payments. They claimed that the university's contract with Higher One Holdings, Inc. subjected them to excessive bank fees and unlawfully disclosed their personal information without consent. The university had contracted with Higher One from 2010 to 2015 to process student loan reimbursements, which involved issuing debit cards and charging various fees.The District Court of the Fourth Judicial District in Missoula County certified three classes of plaintiffs but was later partially reversed by the Montana Supreme Court, which upheld the certification of two classes and reversed the third. The case proceeded to a jury trial, where the jury found in favor of the university, concluding that it did not breach its fiduciary duty, violate privacy rights, or unjustly enrich itself.The Supreme Court of the State of Montana reviewed the case on appeal. The students raised several issues, including the admissibility of evidence regarding their banking practices, the testimony of the university's expert witness, the university's closing arguments, the admission of a fee comparison chart, and the refusal of a burden-shifting jury instruction. The court found that the District Court did not abuse its discretion in its evidentiary rulings, including allowing the university to present evidence about students' banking practices and admitting the fee comparison chart. The court also held that the expert witness's testimony was permissible and that the university's closing arguments did not prejudice the students' right to a fair trial.Ultimately, the Supreme Court of Montana affirmed the District Court's judgment in favor of the University of Montana, upholding the jury's verdict. View "Knudsen v. U. of M." on Justia Law

Simon Soto, a Marine Corps veteran, served from 2000 to 2006 and was medically retired due to post-traumatic stress disorder (PTSD). In 2016, Soto applied for combat-related special compensation (CRSC) and was approved, but his retroactive compensation was limited to six years due to the Barring Act's limitations period. Soto filed a class-action lawsuit arguing that the CRSC statute should displace the Barring Act's limitations period.The United States District Court for the Southern District of Texas granted summary judgment in favor of Soto and the class, holding that the CRSC statute provides its own settlement mechanism, thus displacing the Barring Act. However, the United States Court of Appeals for the Federal Circuit reversed this decision, stating that the CRSC statute does not explicitly grant settlement authority and therefore cannot displace the Barring Act.The Supreme Court of the United States reviewed the case and held that the CRSC statute does confer authority to settle CRSC claims, thereby displacing the Barring Act’s settlement procedures and limitations period. The Court reasoned that the CRSC statute authorizes the Secretary concerned to determine both the validity of CRSC claims and the amount due, creating a comprehensive compensation scheme. Consequently, the Supreme Court reversed the Federal Circuit's decision and remanded the case for further proceedings consistent with this opinion. View "Soto v. United States" on Justia Law

The case involves a class action lawsuit brought by Jacklin Romeo, Susan S. Rine, and Debra Snyder Miller against Antero Resources Corporation. The plaintiffs, who own oil and gas interests in Harrison County, West Virginia, allege that Antero breached the terms of their leases by failing to pay the full one-eighth royalty specified in the leases. They argue that Antero improperly deducted postproduction costs from the gross sale proceeds of the gas, contrary to West Virginia Supreme Court precedents in Wellman v. Energy Resources, Inc. and Estate of Tawney v. Columbia Natural Resources, L.L.C.The United States District Court for the Northern District of West Virginia, presided over by Chief Judge Thomas S. Kleeh, certified two questions to the Supreme Court of Appeals of West Virginia. The first question asked whether the requirements of Wellman and Estate of Tawney extend only to the "first available market" as opposed to the "point of sale" when the duty to market is implicated. The second question asked whether the marketable product rule extends beyond gas to require a lessee to pay royalties on natural gas liquids (NGLs) and, if so, whether lessors share in the cost of processing, manufacturing, and transporting the NGLs to sale.The Supreme Court of Appeals of West Virginia reaffirmed its previous rulings in Wellman and Estate of Tawney, holding that the requirements extend to the point of sale, not just to the first available market. The court also held that royalties are payable on NGLs, but absent express language in the lease, lessors do not share in the costs of processing, manufacturing, and transporting residue gas and NGLs to the point of sale. The court emphasized that any deductions for postproduction costs must be clearly and unambiguously stated in the lease agreements. View "Romeo v. Antero Resources Corporation" on Justia Law