Justia Class Action Opinion Summaries

The case involves Sunny Letot, who owned a vintage Mercedes-Benz sedan that was rear-ended by a driver insured by USAA Casualty Insurance Company. USAA determined that the cost of repair exceeded the car's pre-collision value and deemed it a "total loss" or "salvage." USAA sent Letot checks to cover the car’s pre-collision value and eight days of lost use. Without waiting for Letot to accept its offer, USAA reported to the Texas Department of Transportation (TxDOT) that Letot’s car was salvage. Letot disagreed with USAA’s determinations and never cashed its proffered checks. She claims that USAA’s premature filing led TxDOT to invalidate her vehicle’s regular title, which prevented her from using or selling her sedan. Letot argued that USAA’s actions constituted conversion of her car.The district court certified a class of claimants whose cars USAA had deemed salvage and about whom USAA filed a report within three days of sending the claimant a check for the salvage vehicle. The class sought injunctive relief and damages. The court of appeals affirmed the class certification.The Supreme Court of Texas concluded that class certification was impermissible in this case. The court found that neither Letot nor any class member had standing to pursue injunctive relief, so Letot could not litigate an individual claim for an injunction, much less represent a class. Letot did, however, have standing to seek damages. But as to damages, the certified class did not satisfy the requirements of predominance or typicality. The court reversed the court of appeals’ judgment and remanded the case to the trial court to resolve Letot’s individual claim. View "USAA CASUALTY INSURANCE COMPANY v. LETOT" 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

This case involves a dispute between a lawyer, George Fleming, and his former clients, referred to as the "Wilson plaintiffs". Fleming had represented over 8,000 plaintiffs in a mass-tort action against the manufacturer of a diet pill known as "fen-phen". The Wilson plaintiffs are about 4,000 of Fleming’s former clients. Fleming had spent roughly $20 million to medically screen over 40,000 potential claimants, about 20% of whom became his clients. In 2006, Fleming settled the case for $339 million and reimbursed himself for the costs of the screenings by deducting that amount from the settlement funds. He charged his clients not just for their own medical-screening costs but also for those of approximately 32,000 people who never became his clients and who did not participate in the underlying case. This financial choice led to further litigation, with Fleming as the defendant in various actions brought by his former clients.In the lower courts, Fleming successfully opposed a motion for class certification in a federal court case brought by two of his former clients, arguing that the claims of his former clients were not sufficiently common for aggregate treatment. After the denial of class certification, another group of about 650 former clients sued Fleming for breaches of contract and fiduciary duty. Following a verdict against Fleming in this case, the Wilson plaintiffs moved for summary judgment on the ground that the verdict collaterally estopped Fleming from contesting the merits of their claims against him. Fleming successfully opposed that motion, arguing that the issues presented by the other plaintiffs were not identical to those of the Wilson plaintiffs. The trial court denied the Wilson plaintiffs’ motion for summary judgment without explanation. Later, Fleming moved for summary judgment, asserting defensive collateral estoppel against the Wilson plaintiffs.The Supreme Court of Texas affirmed the judgment of the court of appeals, but for a different reason. The court concluded that Fleming was judicially estopped from establishing an essential component of his summary-judgment motion. The court found that Fleming's assertions in prior litigation clearly and unequivocally contradicted his summary-judgment motion’s assertions regarding whether the Wilson plaintiffs’ legal and factual positions were materially identical to those of the other plaintiffs. The court held that Fleming was estopped from asserting that the thousands of remaining plaintiffs’ claims were materially indistinguishable. View "FLEMING v. WILSON" on Justia Law

The case involves Gerald Forsythe, who filed a class action lawsuit against Teva Pharmaceuticals Industries Ltd. and several of its officers. Forsythe claimed that he and others who purchased or acquired Teva securities between October 29, 2015, and August 18, 2020, suffered damages due to misstatements and omissions by Teva and its officers related to Copaxone, a drug used to treat multiple sclerosis. Teva's shares are dual listed on the New York Stock Exchange and the Tel Aviv Stock Exchange.The District Court granted Forsythe's motion for class certification, rejecting Teva's assertion that the class definition should exclude purchasers of ordinary shares. The Court also rejected Teva's argument that Forsythe could not satisfy Rule 23(b)(3)’s predominance requirement.Teva sought permission to appeal the District Court’s Order granting class certification, arguing that interlocutory review is proper under Federal Rule of Civil Procedure 23(f). Teva contended that the Petition presents a novel legal issue and that the District Court erred in its predominance analysis with respect to Forsythe’s proposed class-wide damages methodology.The United States Court of Appeals for the Third Circuit denied Teva's petition for permission to appeal. The court found that the securities issue did not directly relate to the requirements for class certification, and agreed with the District Court’s predominance analysis. The court also clarified that permission to appeal should be granted where the certification decision itself under Rule 23(a) and (b) turns on a novel or unsettled question of law, not simply where the merits of a particular case may turn on such a question. View "Forsythe v. Teva Pharmaceutical Industries Ltd" on Justia Law

The case involves plaintiffs Christopher Maia and Sean Howarth, who were employed as laborers for defendant IEW Construction Group. The company required them to perform “pre-shift” and “post-shift” work, for which they were not paid. Both Maia and Howarth were laid off in November 2021. In April 2022, they filed a class action complaint alleging that IEW violated the Wage Payment Law (WPL) and the Wage and Hour Law (WHL).The trial judge held that Chapter 212, which amended the WPL and WHL, does not apply retroactively and thus dismissed plaintiffs’ claims for conduct that arose prior to Chapter 212’s effective date of August 6, 2019. The Appellate Division reversed this decision.The Supreme Court of New Jersey granted leave to appeal. The court held that Chapter 212 is to be applied prospectively to conduct that occurred on or after August 6, 2019, not retroactively to conduct that occurred before that date. The trial judge properly dismissed the portions of the complaint relying on Chapter 212 but arising from conduct prior to its effective date. The court reversed the Appellate Division’s judgment, reinstated the trial judge’s order partially dismissing plaintiffs’ complaint, and remanded for further proceedings. View "Maia v. IEW Construction Group" on Justia Law

The case involves a class action lawsuit filed by plaintiff Harold Malmquist against the City of Folsom (City). The plaintiff alleged that the City failed to maintain proper corrosion control measures at its water treatment plant, causing the pH level of its water to rise and become corrosive. This, in turn, led to pinhole leaks in copper pipes receiving the water, damaging persons and property. The plaintiff sought class certification, defining the class as all individuals and entities who have owned or leased real property in the City, plumbed with copper piping receiving water from the City’s plant since February 23, 2015.The trial court denied the plaintiff's motion for class certification. The court found that the plaintiff had not shown that common issues predominated over individual ones. The court reasoned that the existence, cause, and extent of damage to copper piping required individual proof. The court also overruled the plaintiff's objections to the City's expert witness, concluding that the expert was qualified and his opinion was founded on reliable information.On appeal, the Court of Appeal of the State of California Third Appellate District affirmed the trial court's decision. The appellate court found that the trial court did not abuse its discretion in denying class certification. The court agreed with the trial court's conclusion that individual issues predominated over common ones. The court also found no error in the trial court's decision to overrule the plaintiff's objections to the City's expert witness. The court concluded that the expert was qualified and his opinion was founded on reliable information. View "Malmquist v. City of Folsom" on Justia Law

The case revolves around a data privacy dispute involving Pebbles Martin and LCMC Health Holdings and Louisiana Children’s Medical Center (collectively, “LCMC”). Martin filed a class action suit alleging that LCMC violated Louisiana law by embedding tracking pixels onto its website that shared her private health information with third-party websites. The question before the court was not to determine the merits of Martin’s claims, but instead to determine which forum—state or federal—is proper to hear this dispute. LCMC argued that the suit should proceed in federal court because it acted under the direction of a federal officer when it allegedly violated Louisiana law. Martin, however, argued that the suit should remain in state court because LCMC fails to show a basis for federal jurisdiction.LCMC had removed the case to federal court, invoking the federal officer removal statute as the basis for jurisdiction. Martin moved to remand to state court, and the district court granted Martin’s motion, holding that LCMC did not act under the direction of a federal officer when it disclosed private health information to third-party websites. LCMC appealed the remand order.The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court concluded that LCMC did not act under the direction of a federal officer when it embedded tracking pixels onto its website. The court noted that a hospital does not act under the direction of the federal government when it maintains an online patient portal that utilizes tracking pixels. Therefore, the federal officer removal statute does not provide jurisdiction for this case to be heard in federal court. The court affirmed the district court’s order remanding this case to state court. View "Martin v. LCMC Health Holdings" on Justia Law

The case revolves around an oil spill caused by Plains All American Pipeline, L.P. (Plains). The spill resulted in the unlawful discharge of over 142,000 gallons of crude oil into the ocean and onto a beach. The trial court considered restitution for four groups of claimants who alleged losses due to the spill. The People of the State of California appealed the denial of restitution for claimants in two of these groups.The trial court had previously ruled that oil industry claimants were not direct victims of Plains' crimes and accepted mediated settlements in lieu of restitution. It also denied restitution to fishers based on a pending class action lawsuit, declined to consider aggregate proof presented by fishers, and refused to consider Plains' criminal conduct.The Court of Appeal of the State of California Second Appellate District Division Six held that restitution could not be denied based on mediated civil settlements or a class action lawsuit. However, it upheld the trial court's decision to deny restitution to fishers and oil industry workers, stating that they were not direct victims of the pipeline shutdown after the spill. The court remanded the case for consideration of restitution for four fisher claims, but in all other respects, it affirmed the trial court's decision and denied the writ petition. View "People v. Plains All American Pipeline, L.P." on Justia Law

The case involves a group of plaintiffs who filed a class-action lawsuit against KIND, LLC, a snack food company. The plaintiffs alleged that the phrase "All Natural" on the labels of KIND's products was deceptive and misleading. They sought damages on behalf of themselves and three classes, based on common law fraud, as well as consumer protection and false advertising laws in New York, California, and Florida.The District Court for the Southern District of New York granted KIND's motion for summary judgment, concluding that the plaintiffs had failed to establish how a reasonable consumer would understand the term "All Natural." The court held that this was fatal to the plaintiffs' claims because without showing how a reasonable consumer understood the term, the plaintiffs could not explain how or why they were materially deceived. The court also granted KIND's motion to preclude two of the plaintiffs' expert opinions from the summary judgment record and to decertify the classes.On appeal, the United States Court of Appeals for the Second Circuit affirmed the District Court's decision. The appellate court held that the District Court did not abuse its discretion in precluding the opinions of the plaintiffs' experts. The court also held that because the plaintiffs failed to present admissible evidence of what a reasonable consumer would expect of KIND products labeled "All Natural," the District Court did not err in concluding that there was no triable issue of fact as to whether reasonable consumers would be misled by the "All Natural" labeling. The court further held that the plaintiffs' arguments regarding class decertification were moot because the District Court's grant of summary judgment was affirmed. View "In re: Kind LLC "Healthy and All Natural" Litigation" on Justia Law

The case originated as a class action dispute about the underpayment of oil and gas royalties due on wells in Oklahoma. The plaintiff, Chieftain Royalty Company, sued SM Energy Company, the operator of the wells, under various tort theories, including fraud, breach of contract, and breach of fiduciary duty. In 2015, the claims were settled for approximately $52 million. Following the settlement, Chieftain's counsel moved for attorneys’ fees, and Chieftain sought an incentive award for its CEO, Robert Abernathy. Two class members objected to the awards and appealed. The court affirmed the settlement but reversed the attorneys’ fees and incentive awards, remanding to the district court for further proceedings.On remand, the district court re-awarded the fees and incentive award. The class did not receive notice of the 2018 attorneys’ fees motion as required under Federal Rule of Civil Procedure 23(h)(1), so the court vacated the district court order awarding attorneys’ fees and remanded with instructions to direct class-wide notice of the 2018 attorneys’ fees motion and to re-open the period for objections. The court did not reach the merits of the appellate challenge to the re-awarded attorneys’ fees. The court affirmed the district court’s incentive award to Mr. Abernathy. View "Chieftain Royalty Company v. SM Energy Company" on Justia Law