Justia Class Action Opinion Summaries

Plaintiffs Kenneth Bond and Deborah Thibault, on behalf of themselves and a class of others similarly situated, appealed a superior court order granting summary judgment to the defendants, the City of Manchester and Paul Martineau in his official capacity as Commissioner of the Manchester Welfare Department (collectively, the City). In January 2010, the plaintiffs applied for general assistance from the City pursuant to RSA chapter 165. See RSA 165:1, I (2002). On February 24, 2010, the City approved $140.00 per week in rental assistance. On March 18, 2010, the City suspended this assistance for seven days because of the plaintiffs' failure to provide certain documentation, including that which related to $30 the plaintiffs used to buy gas for a vehicle. The City lifted this suspension on March 25, 2010, noting that the plaintiffs were "unable to show compliance with the $30 purchase of vehicle gas that [they] stated [they] had previously purchased through an alternate financial resource." On April 9, 2010, the City revoked an April 8 voucher and denied the plaintiffs all assistance for six months because they had misrepresented information related to their vehicle. The plaintiffs petitioned the superior court to enjoin the City from suspending their assistance. Because the Supreme Court held that RSA 165:1-b and the Guidelines pertaining to rental assistance actually conflict, the Court reversed the trial court's grant of summary judgment in favor of the City and remanded the case for further proceedings.View "Bond v. Martineau" on Justia Law

After a jury trial, Appellant was convicted of rape and sentenced to seventy years' imprisonment. For his only point on appeal, Appellant argued that the circuit court erred in not allowing testimony concerning the victim's prior sexual conduct. Under the state's rape-shield law, evidence of a victim's prior sexual conduct is not admissible by the defendant for any purpose unless the circuit court makes a written determination that such evidence is relevant to a fact in issue and that its probative value outweighs its inflammatory or prejudicial nature. The Supreme Court affirmed, holding that Appellant's arguments were not preserved for appeal. View "Stewart v. State" on Justia Law

Three certified questions came before the court from the Ninth Circuit Court of Appeals concerning application of the farm labor contractors act (FLCA), chapter 19.30 RCW. The primary question asked whether a trial court, if awarding statutory damages under the civil remedies provision of the FLCA must award $500 per plaintiff per violation. Upon review, the Washington Supreme Court answered in the affirmative. The second question asked whether requiring a trial court to award $500 per plaintiff per violation violated due process or public policy; the Court answered in the negative, expressly limiting its analysis and holding on this question to state due process principles and statutes. The third question asked whether the FLCA provided for awarding statutory damages to persons who have not been shown to have been aggrieved by a particular violation. "Because our standing jurisprudence tracks that of the United States Supreme Court, we leave to the Ninth Circuit to answer this question based on its standing jurisprudence and the standing jurisprudence of the Supreme Court." View "Perez-Farias v. Global Horizons, Inc." on Justia Law

The Class Action Fairness Act of 2005 (CAFA) gives federal district courts original jurisdiction over class actions if the matter in controversy exceeds $5 million, 28 U.S.C. 1332(d)(2),(5), and provides that to determine whether a matter exceeds that amount the “claims of the individual class members must be aggregated.” When Knowles filed a proposed class action in Arkansas state court against Standard Fire Insurance, he stipulated that he and the class would seek less than $5 million in damages. Following removal, the district court remanded to state court, concluding that the amount in controversy fell below the CAFA threshold in light of Knowles’ stipulation, although the amount would have fallen above the threshold absent the stipulation. The Eighth Circuit declined to hear an appeal. The Supreme Court vacated and remanded. Knowles’ stipulation does not defeat federal jurisdiction under CAFA. The stipulation does not speak for those Knowles purports to represent; a plaintiff who files a proposed class action cannot legally bind members of the proposed class before the class is certified. CAFA does not forbid a federal court to consider the possibility that a nonbinding, amount-limiting, stipulation may not survive the class certification process. The Court noted CAFA’s objective: ensuring “Federal court consideration of interstate cases of national importance.” View "Standard Fire Ins. Co. v. Knowles" on Justia Law

To recover damages in a private securities-fraud action under section 10(b) of the Securities Exchange Act of 1934 and Securities and Exchange Commission Rule 10b–5, a plaintiff must prove reliance on a material misrepresentation or omission made by the defendant. The Supreme Court has endorsed a “fraud-on-the-market” theory, which permits plaintiffs to invoke a rebuttable presumption of reliance on public, material misrepresentations regarding securities traded in an efficient market. The theory facilitates the certification of securities-fraud class actions by permitting reliance to be proved on a class-wide basis. Connecticut Retirement sought FRCP 23(b)(3) certification of a securities-fraud class action against a biotechnology company (Amgen). The district court certified the class. The Ninth Circuit affirmed, rejecting an argument that Connecticut Retirement was required to prove materiality before class certification under Rule23(b)(3)’s requirement that “questions of law or fact common to class members predominate over any questions affecting only individual members.” The Supreme Court affirmed. Proof of materiality is not a prerequisite to certification of a securities-fraud class action. Materiality is judged by an objective standard and can be proved through evidence common to the class. Failure of proof of materiality would not result in individual questions predominating, but would end the case. A requirement that putative class representatives establish that they executed trades “between the time the misrepresentations were made and the time the truth was r¬vealed” relates primarily to typicality and adequacy of representation, not to the predominance inquiry. The Court rejected Amgen’s argument that, because of pressure to settle, materiality may never be addressed by a court if it is not evaluated at the class-certification stage. The potential immateriality of Amgen’s alleged misrepresentations and omissions was no barrier to finding that common questions predominate. View "Amgen Inc. v. CT Ret. Plans & Trust Funds" on Justia Law

Respondents, current or former employees of petitioner Wal-Mart, sought judgment against the company for injunctive and declaratory relief, punitive damages, and backpay, on behalf of themselves and a nationwide class of some 1.5 million female employees because of Wal-Mart's alleged discrimination against women in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-1 et seq. At issue was whether the certification of the plaintiff class was consistent with Federal Rules of Civil Procedure 23(a) and (b)(2). The Court held that certification of the plaintiff class was not consistent with Rule 23(a) where proof of commonality necessarily overlapped with respondents' merits contention that Wal-mart engaged in a pattern or practice of discrimination and without some glue holding together the alleged reasons for the employment decisions, it would be impossible to say that examination of all the class members' claims would produce a common answer to the crucial discrimination question. The Court concluded that in a company Wal-Mart's size and geographical scope, it was unlikely that all managers would exercise their discretion in a common way without some common direction and respondents' attempt to show such direction by means of statistical and anecdotal evidence fell well short. The Court also held that respondents' backpay claims were improperly certified under Rule 23(b)(2) where claims for monetary relief could not be certified under the rule. Accordingly, the judgment of the Court of Appeals was reversed.View "Wal-Mart Stores, Inc. v. Dukes, et al." on Justia Law

In this case, a Federal District Court enjoined a state court from considering a plaintiff's request to approve a class action. The District Court did so because it had earlier denied a motion to certify a class in a related case, brought by a different plaintiff against the same defendant alleging similar claims. The federal court thought its injunction appropriate to prevent relitigation of the issue it had decided. The Court held to the contrary and found that, in issuing the order to a state court, the federal court exceeded its authority under the "relitigation exception" of the Anti-Injunction Act ("Act"), 28 U.S.C. 2283, where the statutory provision permitted a federal court to enjoin a state proceeding only in rare cases, when necessary to "protect or effectuate [the federal court's] judgments." The Court held that the standard was not met in this case for two reasons. First, the issue presented in the state court was not identical to the one decided in the federal tribunal. Second, the plaintiff in the state court did not have the requisite connection to federal suit to be bound by the District Court's judgment.View "Smith v. Bayer Corp." on Justia Law

Respondent, First Derivative Traders, representing a class of stockholders in petitioner Janus Capital Group, Inc. ("JCG"), filed a private action under the Securities and Exchange Commission ("SEC") Rule 10b-5, alleging that JCG and its wholly owned subsidiary, petitioner Janus Capital Management LLC ("JCM"), made false statements in mutual funds prospectuses filed by Janus Investment Fund, for which JCM was the investment adviser and administrator, and that those statements affected the price of JCG's stock. Although JCG created Janus Investment Fund, it was a separate legal entity owned entirely by mutual fund investors. At issue was whether JCM, a mutual fund investment adviser, could be held liable in a private action under Rule 10b-5 for false statements included in its client mutual funds' prospectuses. The Court held that, because the false statements included in the prospectuses were made by Janus Investment Fund, not by JCM, JCM and JCG could not be held liable in a private action under Rule 10b-5. The Court found that, although JCM could have been significantly involved in preparing the prospectuses, it did not itself "make" the statements at issue for Rule 10b-5 purposes where its assistance in crafting what was said was subject to Janus Investment Fund's ultimate control. Accordingly, respondent had not stated a claim against JCM under Rule 10b-5 and the judgment of the Fourth Circuit was reversed.View "Janus Capital Group, Inc. v. First Derivative Traders" on Justia Law

Petitioner, the lead plaintiff in a putative securities fraud class action, filed suit against respondent alleging violations under section 10(b) of the Securities and Exchange Act of 1934, 15 U.S.C. 78a et seq., and Securities and Exchange Commission Rule 10b-5, and sought to have its proposed class certified pursuant to Federal Rule of Civil Procedure 23. The Court of Appeals affirmed the District Court's conclusion that the "loss causation" element of class certification was not satisfied and denied class certification. At issue was whether securities fraud plaintiffs must also prove loss causation in order to obtain class certification. The Court held that securities fraud plaintiffs need not prove loss causation in order to obtain class certification and that the Court of Appeals' rule contravened Basic Inc. v. Levinson's fundamental premise that an investor presumptively relied on a misrepresentation so long as it was reflected in the market price at the time of his transaction. The Court also distinguished that, where loss causation was a familiar and distinct concept in securities law, it was not price impact. Accordingly, the Court vacated the judgment and remanded for further proceedings.View "Erica P. John Fund, Inc. v. Halliburton Co., et al." on Justia Law

Respondents, on behalf of beneficiaries of the CIGNA Corporation's ("CIGNA") Pension Plan, challenged the new plan's adoption, claiming that CIGNA's notice of the changes was improper, particularly because the new plan in certain respects provided them with less generous benefits. At issue was whether the district court applied the correct legal standard, namely, a "likely harm" standard, in determining that CIGNA's notice violations caused its employees sufficient injury to warrant legal relief. The Court held that although section 502(a)(1)(B) of the Employee Retirement Income Security Act of 1974 ("ERISA"), 29 U.S.C. 1022(a), 1024(b), 1054(h), did not give the district court authority to reform CIGNA's plan, relief was authorized by section 502(a)(3), which allowed a participant, beneficiary, or fiduciary "to obtain other appropriate relief" to redress violations of ERISA "or the [plan's] terms." The Court also held that, because section 502(a)(3) authorized "appropriate equitable relief" for violations of ERISA, the relevant standard of harm would depend on the equitable theory by which the district court provided relief. Therefore, the Court vacated and remanded for further proceedings.View "CIGNA Corp. v. Amara et al." on Justia Law