Justia Class Action Opinion Summaries

Appellants John Doe, Jane Doe 1, Jane Doe 2 and Jane Doe 3 separately sued Respondents the Bishop of Charleston and the Bishop of the Diocese of Charleston in his official capacity (respondents). The cases were consolidated, and respondents moved to dismiss on the pleadings. The trial court granted the motion. In 2007, respondents entered into a class action settlement agreement (the settlement) to settle the claims of "[a]ll individuals born on or before August 30, 1980 who, as minors, were sexually abused at any time by agents or employees of the Diocese of Charleston" as well as their spouses and parents, except those whose claims had been independently resolved. The settlement established a fund from which awards would be made to claimants who established their sexual abuse claims by arbitration. Appellants alleged they did not receive notice of the settlement. In 2009, after the claims and opt-out period provided for in the settlement had expired, they brought suit alleging claims of the type covered by the settlement. After careful consideration of the trial court record, the Supreme Court concluded: (1) the language of the settlement did not waive its res judicata effect as to future claimants, so that appellants were not entitled to treatment as class claimants; (2) however, dismissal on the pleadings was not warranted on the questions whether appellants were deprived of notice or adequate representation in the underlying class settlement and, if so, whether the statute of limitations was tolled on their claim of negligent supervision. If appellants could establish on remand that they were denied due process owing to lack of notice or because of inadequate representation in the class action proceedings, and that the statute of limitations was tolled, the Supreme Court held that they could proceed on their claims. View "Doe v. The Bishop of Charleston" on Justia Law

Plaintiffs were five independent retail pharmacies licensed in California, and Defendants were prescription drug claims processors. In 2002, Plaintiffs filed a federal class action suit alleging that Defendants failed to comply with Cal. Civil Code 2527, which requires prescription drug claims processors to compile and summarize information on pharmacy fees and transmit that information to their clients. The district court dismissed the cases for lack of standing without reaching the merits. On appeal, the Ninth Circuit Court of Appeals concluded that Plaintiffs had standing, reversed the district court, and remanded. On remand, Defendants moved for judgment on the pleadings, contending that section 2527 unconstitutionally compels speech in violation of the California and U.S. Constitutions. The district court denied the motions. On appeal, the Ninth Circuit asked the California Supreme Court to answer a question of state law. The Supreme Court answered by holding (1) section 2527 implicates the right to free speech guaranteed by the California Constitution and is subject to rational basis review; and (2) the statute satisfies that standard because the compelled factual disclosures are reasonably related to the Legislature's legitimate objective of promoting informed decisionmaking about prescription drug reimbursement rates.View "Beeman v. Anthem Prescription Mgmt." on Justia Law

Steve Sangwin, a State employee, was a qualified subscriber and beneficiary of the State of Montana Employee Benefits Plan (Plan), which was administered by Blue Cross and Blue Shield of Montana (BCBS). Steve's daughter, McKinley, was also a beneficiary under the Plan. This case arose after BCBS denied a preauthorization request for a medical procedure for McKinley on the grounds that the procedure was "experimental for research." Steve and his wife (collectively, the Sangwins) initiated this action by filing an amended complaint setting forth five counts, including a request for certification of a class action. The Sangwins defined class members as other beneficiaries of the Plan who had their employee benefits denied by the State based on the experimental exclusion for research in the past eight years. The district court granted the Sangwins' motion for class certification. The State appealed. The Supreme Court (1) affirmed the district court's order defining the class; but (2) reversed and remanded with respect to the question certified for class treatment, holding that the district court abused its discretion in specifying for class treatment the question of whether the State breached its contract of insurance with the plaintiffs.View "Sangwin v. State" on Justia Law

Helmerich & Payne, Inc. (H&P) appeals a judgment in favor of the plaintiffs, who are a class of oil and gas royalty owners. The class alleged that the defendant breached contractual and fiduciary duties by allowing uncompensated drainage of natural gas to occur from the leases and that the defendant engaged in constructive fraud and was unjustly enriched by failing to pay royalty amounts that the class alleged were included in a settlement between the defendant and ANR Pipeline. The jury returned verdicts on three alternative theories of recovery. The trial court judge granted judgment that included disgorgement of profits based on a sum the trial court found unjustly enriched H&P. On appeal, the Court of Civil Appeals affirmed in part and reversed in part, and remanded with instructions. H&P argued on appeal to the Supreme Court that: (1) the trial court erred in its jury instructions for uncompensated drainage that barred consideration of counterdrainage; (2) the appellate court erred by allowing a breach of contract claim to be recast as an equitable unjust enrichment claim; (3) the appellate court erred in affirming a "mathematically impossible" jury verdict on plaintiffs' constructive fraud claims; and (4) the appellate court erred in affirming the constructive fraud damage award notwithstanding that no fraud claim was ever certified. After review, the Supreme Court found: (1) the trial court committed no reversible error; (2) the jury found that plaintiffs did not prove by clear and convincing evidence that H&P acted in reckless disregard for the rights of others, nor that H&P acted intentionally and with malice toward others; (3) because the Court reversed the judgment based on equity, the third reason for granting certiorari was answered; and (4) having reversed the constructive fraud damage award, the Court held this issue was moot. View "Krug v. Helmerich & Payne, Inc." on Justia Law

In consolidated appeals, defendants the Alabama Department of Corrections, various department officials, and Governor Robert Bentley, appealed in case no. 1111588, the trial court's determination limiting certain deductions from work-release earnings for inmates. In case no. 1120264, Jerry Mack Merritt (as sole representative of the plaintiff class) cross-appealed, raising numerous challenges to the trial court's final judgment. After its review, the Supreme Court dismissed the appeal in case no. 1120264 as untimely filed; in case no. 1111588, the Court reversed and remanded. The Court found that the department's interpretation of section 14-8-6 as permitting its collection of charges, which were not incident to the inmate's confinement, in excess of a 40% withholding cap established by that statute was both reasonable and consistent with the statutory language. View "Thomas v. Merritt" on Justia Law

Diamante, LLC (Diamante) operated a private-membership golf club. There were 450 privately owned lots around the golf club and clubhouse that were located in two subdivisions. Supplemental declarations of covenants and restrictions ran with the land and created certain obligations and restrictions, called tie-in rights, that required, among other things, lot owners to become full golf members of the Diamante Country Club and to pay monthly dues to the Club. Appellees filed a declaratory judgment action asking the circuit court to declare the tie-in rights unenforceable due to Diamante's failure to collect monthly dues from all full golf members. Appellees filed a motion for class certification. The circuit court certified the class, defining the class as current owners of the 450 lots in the subdivisions with limited exclusions. Diamante appealed. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in granting class certification.View "Diamante, LLC v. Dye" on Justia Law

Appellant was convicted of two counts of aggravated robbery, two counts of theft of property, and one count of second-degree battery. After the court of appeals affirmed on direct appeal, Appellant filed a petition for postconviction relief, alleging ineffective assistance of counsel. The circuit court denied the petition after a hearing. The Supreme Court affirmed, holding that trial counsel was not ineffective (1) for failing to move for a directed verdict at trial, as a directed-verdict motion would not have been successful; (2) for "opening the door" to certain testimony, as counsel's tactical decision about how to cross-examine the witness was supported by reasonable professional judgment; and (3) in investigating and preparing Appellant's case.View "Mason v. State" on Justia Law

The underlying class action here was brought against Southern Financial Life Insurance Company, which sold credit life and disability insurance through lending institutions, by purchasers of Southern Financial's credit life and disability policies. During the discovery phase, the trial court entered an order compelling Southern Financial to produce certain loan information and documents regarding the putative class members and the insurance sold to them. Southern Financial did not comply with the order, arguing that the loan information was not in its "possession, custody or control" within the meaning of Ky. R. Civ. P. 34.01, but rather, the information was in the possession of the individual lenders. After applying principles of general agency law, the trial court overruled the objection. Southern Financial subsequently sought a writ of prohibition to prevent the trial court's enforcement of the discovery order. The court of appeals declined to issue a writ. The Supreme Court affirmed, holding that Southern Financial was legally in control of the information it was compelled to disclose in the trial court's order, and therefore, the trial court committed no error.View "S. Fin. Life Ins. Co. v. Pike Circuit Court" on Justia Law

Defendant was charged with driving under the influence of alcohol and driving with a blood-alcohol concentration of 0.08 percent or more. During the trial proceedings, the trial court excluded expert witness testimony challenging the reliability of the breach-alcohol testing machines used on Defendant. The jury was unable to reach a verdict on the generic charge but found Defendant guilty of driving with 0.08 percent or more of alcohol in his blood. The court of appeals reversed, concluding that the trial court committed prejudicial error in excluding the challenged expert testimony. The Supreme Court reversed and affirmed Defendant's conviction, holding that the trial court properly excluded the challenged expert testimony, holding that the fundamental reliability of a federally approved, properly calibrated and employed breath-testing machine used in the application and enforcement of a per se statute is a matter that has been determined as policy by the Legislature, and a defendant's expert witness may not invite a jury to nullify that determination in the manner at issue here.View "People v. Vangelder" on Justia Law

In November 2002, Appellee Beverly Roethlein, an Allentown taxpayer, filed a class action complaint against Portnoff Law Associates, Ltd., and Michelle Portnoff, Esquire (the firm's sole shareholder) seeking recovery for unjust enrichment and violations of Section 502 of Act 6, Pennsylvania’s Loan Interest and Protection Law. Portnoff serves as a private tax collector for various municipalities and school districts, and had contracts with 22 municipalities to represent them in the collection of delinquent real estate taxes. Taxpayers would be charged $150 for the opening of a file and preparation of a demand letter; $150 for the filing of a lien and preparation of a second letter; and $150 for preparation and filing of a writ of scire facias. The contracts required the municipalities to enact an ordinance or resolution authorizing Portnoff to impose legal fees upon the delinquent taxpayer. From the time a file was sent to her for collection, Portnoff began charging 10% interest on the principal. The issue before the Supreme Court in this case was whether the Loan Interest and Protection Law provided taxpayers with a cause of action to challenge costs imposed for the collection of delinquent taxes or to seek damages and attorneys’ fees for improperly-imposed costs. Furthermore, at issue was whether Section 7103 of the Municipal Claims and Tax Liens Act authorized a municipality to recover the administrative costs it incurs in collecting delinquent taxes. After review, the Court concluded that Act 6 does not provide a cause of action for claims which do not involve the loan or use of money. Furthermore, the Court concluded Section 7103 of the MCTLA allows a municipality to recover fees it pays to a third-party tax collector for the purpose of collecting delinquent taxes. In light of these conclusions, the Court reversed the decision of the Commonwealth Court, and remanded the case to the Commonwealth Court for further proceedings. View "Roethlein v. Portnoff Law Assoc." on Justia Law