Justia Class Action Opinion Summaries

The case involves Karen Frohn, who applied for and received a life insurance policy from Globe Life and Accident Insurance Company on behalf of her husband, Greg Frohn. After Greg's death, Karen submitted a claim for death benefits, which Globe denied. Karen then sued Globe, both individually and on behalf of a putative class of beneficiaries, challenging the denial of her claim.Globe moved for summary judgment, arguing that it was entitled to rescind the life insurance policy because Karen was not truthful in her application for insurance. The district court granted Globe’s motion, barring Karen from recovery on her claims against Globe. Karen also asked the court to redact certain portions of that order, but the district court published it without any redactions. Karen appealed these decisions.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that Karen had voluntarily waived her husband's physician-patient privilege by signing an Authorization for Release, allowing Globe to access Greg's medical records. The court also found that Globe was entitled to rescind the policy under Ohio law because Karen had made material misrepresentations in the insurance application. The court concluded that Globe's defense barred Karen's breach-of-contract and bad-faith claims. View "Frohn v. Globe Life and Accident Ins Co" on Justia Law

The case involves Quintin Scott, a former pretrial detainee at the Cook County Jail, who filed a class action lawsuit against Cook County and its sheriff. Scott alleged that the county provided him and other pretrial detainees with inadequate dental care, violating the Fourteenth Amendment. The district court refused to certify the class, and Scott settled his individual claim but reserved his right to appeal the class ruling and to seek an incentive award for his role as the named plaintiff.The County argued that Scott lacked standing to pursue the class aspects of the case, contending that he no longer had a live interest in the litigation and that courts were forbidden from granting incentive awards. The United States Court of Appeals for the Seventh Circuit disagreed, finding that Scott had standing and that incentive awards were permissible. The court also concluded that the district court had abused its discretion in denying class certification, as it had misapplied a previous decision and used too strict a standard.The Court of Appeals vacated the district court's order and remanded the case for further proceedings, noting that the district court was free to revise the class definition as needed to address any overbreadth issues. The court also noted that the district court had not addressed whether the proposed class met the requirements of numerosity and adequacy of representation, which must be satisfied before the class can be certified. View "Scott v. Dart" on Justia Law

A group of individuals, including a minor, filed a class action lawsuit against Warner Bros. Entertainment, Inc. for alleged misrepresentations related to the mobile application Game of Thrones: Conquest (GOTC). The plaintiffs claimed that Warner Bros. engaged in false and misleading advertising within the game. In response, Warner Bros. moved to compel arbitration of all claims based on the GOTC Terms of Service, which users agree to by tapping a “Play” button located on the app’s sign-in screen. The district court denied Warner Bros.' motion, finding that the notice of the Terms of Service was insufficiently conspicuous to bind users to them.The case was appealed to the United States Court of Appeals for the Ninth Circuit. The lower court had found that Warner Bros. failed to provide reasonably conspicuous notice of its Terms of Service, thus denying the motion to compel arbitration. The district court focused on whether the context of the transaction put the plaintiffs on notice that they were agreeing to the Terms of Service, concluding that the app did not involve a continuing relationship that would require some terms and conditions.The Ninth Circuit Court of Appeals reversed the district court's decision. The appellate court held that the district court erred in finding that Warner Bros. failed to provide reasonably conspicuous notice. The court found that the context of the transaction and the placement of the notice were both sufficient to provide reasonably conspicuous notice. The court also rejected the plaintiffs' argument that the arbitration agreement was unconscionable due to its ban on public injunctive relief. The court concluded that the unenforceability of the waiver of one’s right to seek public injunctive relief did not make either this provision or the arbitration agreement unconscionable or otherwise unenforceable. The case was remanded for further proceedings. View "KEEBAUGH V. WARNER BROS. ENTERTAINMENT INC." on Justia Law

A class of stock purchasers alleged that Anadarko Petroleum Corporation fraudulently misrepresented the potential value of its Shenandoah oil field project in the Gulf of Mexico, violating federal securities law. The plaintiffs claimed that a decline in Anadarko’s stock price resulted from the company's disclosure that the Shenandoah project was dry and that Anadarko was taking a significant write-off for the project. The plaintiffs invoked the Basic presumption, a legal principle that allows courts to presume an investor's reliance on any public material misrepresentations if certain requirements are met.The District Court for the Southern District of Texas certified the class, relying on new evidence presented by the plaintiffs in their reply brief. Anadarko argued that it was not given a fair opportunity to respond to this new evidence and appealed the decision.The United States Court of Appeals for the Fifth Circuit agreed with Anadarko, stating that the district court should have allowed a sur-reply when the plaintiffs presented new evidence in their reply brief. The court held that when a party raises new arguments or evidence for the first time in a reply, the district court must either give the other party an opportunity to respond or decline to rely on the new arguments and evidence. The court also agreed that the district court failed to perform a full Daubert analysis, a standard for admitting expert scientific testimony. The court vacated the class certification order and remanded the case for further proceedings. View "Georgia Firefighters' Pension Fund v. Anadarko Petroleum Corp." on Justia Law

This case involves a dispute between plaintiffs Michelle Beverage and Joseph Mejia, and defendant Apple, Inc. The plaintiffs filed a class action complaint alleging that Apple's restrictive contractual terms and coercive conduct towards software developers on its App Store constituted unlawful and unfair practices that violated the Cartwright Act and the Unfair Competition Law (UCL). The plaintiffs specifically focused on Apple's treatment of one developer, Epic Games, Inc., and its gaming application, Fortnite. The trial court sustained a demurrer brought by Apple without leave to amend, applying the Colgate doctrine and the holding of Chavez v. Whirlpool Corporation. The court determined that the plaintiffs did not and could not state causes of action under either legal regime as a matter of law.The trial court's decision was based on the application of the Colgate doctrine and the holding of Chavez v. Whirlpool Corporation. The court found that the plaintiffs did not and could not state causes of action under either the Cartwright Act or the UCL as a matter of law. The plaintiffs appealed only one aspect of the trial court's ruling, arguing that the court erred by relying on Chavez to sustain the demurrer to their UCL cause of action alleging unfair practices by Apple towards Epic Games.The Court of Appeal of the State of California Sixth Appellate District affirmed the trial court's judgment. The appellate court disagreed with the plaintiffs' argument that Chavez was inconsistent with the California Supreme Court’s decision in Cel-Tech Communications, Inc. v. Los Angeles Cellular Telephone Company. The court found that the trial court correctly relied on Chavez to sustain the demurrer without leave to amend. The court held that the plaintiffs did not state a claim as a matter of law under the "unfair" prong of the UCL, considering the trial court's ruling that Apple's practices constituted permissible unilateral conduct. View "Beverage v. Apple, Inc." on Justia Law

The case involves a consumer class action against Nutramax Laboratories, Inc. and Nutramax Laboratories Veterinary Sciences, Inc. (collectively, “Nutramax”), alleging that Nutramax violated the California Consumers Legal Remedies Act by falsely marketing its pet health product, Cosequin, as promoting healthy joints in dogs. The plaintiffs, Justin Lytle and Christine Musthaler, claimed that Cosequin provided no such health benefits. The district court certified a class of California purchasers of certain Cosequin products who were exposed to the allegedly misleading statements.The district court had certified the class based on the proposed damages model of Plaintiffs’ expert, Dr. Jean-Pierre Dubé, to find that common questions predominated as to injury. Nutramax appealed, arguing that the district court erred in relying on an unexecuted damages model to certify the class and that the element of reliance was not susceptible to common proof.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The appellate court held that there was no general requirement that an expert actually apply to the proposed class an otherwise reliable damages model in order to demonstrate that damages are susceptible to common proof at the class certification stage. The court also rejected Nutramax’s contention that the district court incorrectly concluded that the element of reliance was susceptible to common proof. The district court properly found that classwide reliance may be established under the CLRA through proof that a misrepresentation is material. View "LYTLE V. NUTRAMAX LABORATORIES, INC." on Justia Law

The case involves a class action lawsuit brought against the Illinois Department of Corrections (IDOC) by four parents who were convicted of sex offenses and were on mandatory supervised release (MSR). The plaintiffs challenged an IDOC policy that restricts contact between a parent convicted of a sex offense and their minor child while the parent is on MSR. The plaintiffs argued that this policy violates their Fourteenth Amendment rights to procedural and substantive due process.The district court upheld the policy, with two exceptions. It ruled that the policy's ban on written communications was unconstitutional and that IDOC must allow a parent to submit a written communication addressed to their child for review and decision within seven calendar days. The plaintiffs appealed, challenging the policy's restrictions on phone and in-person contact.The United States Court of Appeals for the Seventh Circuit affirmed in part and reversed in part. The court agreed with the district court that the policy does not violate procedural due process. However, it held that the policy's ban on phone contact violates substantive due process. The court found that call monitoring is a ready alternative to the phone-contact ban that accommodates the plaintiffs’ right to enjoy the companionship of their children at a de minimis cost to IDOC’s penological interests. View "Montoya v. Jeffreys" on Justia Law

The case involves Sherry and David Lewis, who sued their auto insurer, GEICO, for allegedly breaching their insurance contract when their car was totaled. The Lewises claimed that GEICO undercompensated them by applying a "condition adjustment" that artificially reduced its valuation of their car and by failing to reimburse them for taxes and fees necessary to replace the car. They sought to certify a class of similarly underpaid insureds for each instance of underpayment.The District Court certified both classes under Federal Rule of Civil Procedure 23. GEICO appealed the decision, challenging the certification of the classes.The United States Court of Appeals for the Third Circuit affirmed the order certifying the class for the taxes-and-fees claim. However, the court found that the Lewises lacked standing to bring the condition-adjustment claim as they failed to show that GEICO caused them concrete harm when it applied the condition adjustment. Therefore, the court vacated the District Court’s order in part and remanded with instructions to dismiss the condition-adjustment claim.Regarding the taxes-and-fees claim, the court found that the Lewises met the requirements for standing as they alleged financial harm stemming from GEICO's pre-2020 practice of declining to pay taxes and fees to lessee insureds. The court also found that the class was ascertainable, meeting the requirements for class certification. View "Lewis v. GEICO" on Justia Law

The plaintiff, Ryan S., filed a class action lawsuit against UnitedHealth Group, Inc. and its subsidiaries (collectively, “UnitedHealthcare”) under the Employee Retirement Income Security Act of 1974 (“ERISA”). He alleged that UnitedHealthcare applies a more stringent review process to benefits claims for outpatient, out-of-network mental health and substance use disorder (“MH/SUD”) treatment than to otherwise comparable medical/surgical treatment. Ryan S. asserted that by doing so, UnitedHealthcare violated the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 (“Parity Act”), breached its fiduciary duty, and violated the terms of his plan.The district court granted UnitedHealthcare’s motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) based primarily on its conclusions that Ryan S. failed to allege that his claims had been “categorically” denied and insufficiently identified analogous medical/surgical claims that he had personally submitted and UnitedHealthcare had processed more favorably.The United States Court of Appeals for the Ninth Circuit reversed in part and affirmed in part the district court’s judgment. The panel concluded that Ryan S. adequately stated a claim for a violation of the Parity Act. The panel explained that an ERISA plan can violate the Parity Act in different ways, including by applying, as Ryan S. alleged here, a more stringent internal process to MH/SUD claims than to medical/surgical claims. The panel also concluded that Ryan S. alleged a breach of fiduciary duty. However, as Ryan S. failed to identify any specific plan terms that the alleged practices would violate, the panel affirmed the dismissal of his claims based on a violation of the terms of his plan. The case was remanded for further proceedings. View "Ryan S. v. UnitedHealth Group, Inc." on Justia Law

Yasmin Varela filed a class action lawsuit against State Farm Mutual Automobile Insurance Company (State Farm) after a car accident. Varela's insurance policy with State Farm entitled her to the "actual cash value" of her totaled car. However, she alleged that State Farm improperly adjusted the value of her car based on a "typical negotiation" deduction, which was not defined or mentioned in the policy. Varela claimed this deduction was arbitrary, did not reflect market realities, and was not authorized by Minnesota law. She sued State Farm for breach of contract, breach of the covenant of good faith and fair dealing, unjust enrichment, and violation of the Minnesota Consumer Fraud Act (MCFA).State Farm moved to dismiss the complaint, arguing that Varela's claims were subject to mandatory, binding arbitration under the Minnesota No-Fault Automobile Insurance Act (No-Fault Act). The district court granted State Farm's motion in part, agreeing that Varela's claims for breach of contract, breach of the covenant of good faith and fair dealing, and unjust enrichment fell within the No-Fault Act's mandatory arbitration provision. However, the court found that Varela's MCFA claim did not seek the type of relief addressed by the No-Fault Act and was neither time-barred nor improperly pleaded, and thus denied State Farm's motion to dismiss this claim.State Farm appealed, arguing that Varela's MCFA claim was subject to mandatory arbitration and should have been dismissed. However, the United States Court of Appeals for the Eighth Circuit dismissed the appeal for lack of jurisdiction. The court found that State Farm did not invoke the Federal Arbitration Act (FAA) in its motion to dismiss and did not file a motion to compel arbitration. The court concluded that the district court's order turned entirely on a question of state law, and the policy contained no arbitration provision for the district court to "compel." Therefore, State Farm failed to establish the court's jurisdiction over the interlocutory appeal. View "Varela v. State Farm Mutual Automobile Insurance Co." on Justia Law