Justia Class Action Opinion Summaries
Chambers v. Whirlpool Corp.
In a class action lawsuit regarding faulty Whirlpool dishwashers, the Ninth Circuit affirmed the district court's approval of a class settlement, but vacated and remanded the $14.8 million attorney's fees award. The panel held that the Class Action Fairness Act's (CAFA) attorney's fee provisions apply to all federal class actions; the district court improperly used a lodestar-only method to calculate attorney's fees for the coupon portion of the settlement where that methodology potentially inflates the amount of attorney's fees in proportion to the results achieved for the class because the coupons may end up providing minimal benefit to the class; the district court erred in awarding a 1.68 lodestar multiplier; and the district court did not abuse its discretion in approving the settlement.On remand, the panel instructed the district court to apply a percentage-of-redemption value methodology for the coupon portion of a settlement, and use a lodestar method for the non-coupon part of the relief. In the alternative, the panel stated that the district court may use a lodestar-only methodology, but only if it does not consider the coupon relief or takes into account its redemption value. View "Chambers v. Whirlpool Corp." on Justia Law
Martinez-Cuevas v. DeRuyter Bros. Dairy, Inc.
This case concerned the constitutionality of RCW 49.46.130(2)(g), the provision exempting agricultural workers from the overtime pay requirement set out in the Washington Minimum Wage Act, ch. 49.46 RCW. Jose Martinez-Cuevas and Patricia Aguilar worked for DeRuyter Brothers Dairy as milkers. DeRuyter milkers used mechanized equipment to milk close to 3,000 cows per shift, 24 hours a day, three shifts a day, 7 days a week. In 2016, Martinez-Cuevas and Aguilar filed the present class action suit along with about 300 fellow DeRuyter dairy workers, claiming that DeRuyter failed to pay minimum wage to dairy workers, did not provide adequate rest and meal breaks, failed to compensate pre- and post-shift duties, and failed to pay overtime. The complaint also sought a judgment declaring RCW 49.46.130(2)(g) unconstitutional. The trial court granted partial summary judgment to the class, finding the exemption violated article I, section 12 of the Washington Constitution and the equal protection clause. After review, the Washington Supreme Court concurred with the trial court and affirmed that judgment. View "Martinez-Cuevas v. DeRuyter Bros. Dairy, Inc." on Justia Law
Binder v. Cuyahoga County
The Supreme Court reversed the judgment of the court of appeals affirming the trial court's class certification order and vacated the class certification order, holding that Ohio Rev. Code 124.34 does not authorize civil service employees to file a civil action in common pleas court to address an alleged reduction in pay in violation of section 124.34.Appellees and other named class representatives filed two consolidated class action lawsuits against Cuyahoga County seeking damages and a declaratory judgment that the county reduced their compensation, in violation of section 124.34. The trial court certified a class. The Supreme Court reversed, holding (1) section 124.34 does not authorize civil service employees to file a civil action in common pleas court for an alleged reduction in pay in violation of the statute; and (2) because Appellees' complaints did not state a cause of action for which relief may be granted, the trial court erred in certifying a class based on those claims. View "Binder v. Cuyahoga County" on Justia Law
Baker v. USD 229 Blue Valley
Plaintiff-appellant Terri Baker appealed the dismissal of this putative class action for lack of standing. She sued on behalf of herself and her son, S.F.B., to challenge Kansas laws and school district policies that: (1) required children to be vaccinated to attend school and participate in child care programs; and (2) provided a religious exemption from these requirements. She claimed these immunization laws and policies violated various federal and state constitutional provisions and statutes. Baker argued she and S.F.B. had standing because the immunization requirements and religious exemptions injured them in two ways: (1) the District misapplied Kansas law when it granted a religious exemption for S.F.B. to attend preschool despite being unvaccinated - her fear that the District would revoke S.F.B.'s religious exemption was an injury in fact that established standing; and (2) Baker "would like the option" of placing S.F.B. in a non-accredited private school (i.e., home school), school programs, or licensed child care - she contended Kansas law inhibited her from exercising these options and caused an injury in fact because she would be unable to secure a religious exemption for S.F.B. if she tried. Finding no reversible error in the district court's dismissal, the Tenth Circuit affirmed. View "Baker v. USD 229 Blue Valley" on Justia Law
Koppers, Inc. v. Trotter
The Supreme Court affirmed the order of the circuit court granting class certification of Plaintiffs' complaint, holding that the circuit court did not abuse its discretion in certifying the class.Plaintiffs were hourly employees of Koppers, Inc. Plaintiffs filed this action against Koppers alleging that Koppers did not pay them for working overtime in violation of the Arkansas Minimum Wage Act (AMWA), Ark. Code Ann. 11-4-211(a). Plaintiffs filed a motion to certify a class. The circuit court granted the motion. Koppers appealed, arguing that its liability could not be established on a classwide basis because whether a plaintiff could recover depended on individualized facts. The Supreme Court affirmed, holding that the circuit court's findings on commonality, predominance, and superiority were not in error. View "Koppers, Inc. v. Trotter" on Justia Law
Muransky v. Godiva Chocolatier, Inc.
Plaintiff filed suit alleging that Godiva chocolate stores had printed too many credit card digits on hundreds of thousands of receipts over the course of several years, and pointed out that those extra numbers were prohibited under a federal law aimed at preventing identity theft. After the parties agreed on a class settlement, the Supreme Court issued Spokeo, Inc. v. Robins, which held that a party does not have standing to sue when it pleads only the bare violation of a statute.The Eleventh Circuit held that plaintiff has no standing because he alleged only a statutory violation and not a concrete injury. In this case, plaintiff alleged that a cashier handed him a receipt containing some of his own credit card information printed on it. Although the receipt violated the law because it contained too many digits, the court explained that plaintiff has alleged no concrete harm or material risk of harm stemming from the violation. Therefore, this amounts to nothing more than a "bare procedural violation, divorced from concrete harm." Consequently, the court cannot evaluate the fairness of the parties' settlement and vacated the district court's order approving it. View "Muransky v. Godiva Chocolatier, Inc." on Justia Law
Chavez v. Occidental Chemical Corp
The Court of Appeals answered questions certified to it by the United States Court of Appeals for the Second Circuit regarding whether New York recognizes so-called American Pipe tolling of the statute of limitations for absent class members of a putative class action filed in another jurisdiction.In 2012, Plaintiffs filed individual lawsuits alleging injuries based upon the manufacturing of a nematicide by Occidental Chemical Corporation. The cases were consolidated, and the action was transferred to the United States District Court for the Southern District of New York. Occidental moved for judgment on the pleadings, arguing that Plaintiffs' claims were time-barred under New York law. Plaintiffs argued in response that a putative class action originally filed in Texas state court in 1993 had tolled the applicable three-year statute of limitations. The New York District Court Judge denied the motion and certified an interlocutory appeal to the Second Circuit, which, in turn, certified questions to the Court of Appeals. The Court of Appeals answered (1) New York recognizes American Pipe & Construction Co. v. Utah, 414 US 538 (1974), tolling for absent class members of putative class actions filed in other state and federal courts; and (2) a non-merits dismissal of class certification, as occurred here in 1995, extinguishes tolling. View "Chavez v. Occidental Chemical Corp" on Justia Law
Kramer v. Fergus Farm Mutual Insurance Co.
The Supreme Court affirmed in part and reversed in part the judgment of the district court granting class certification in this action alleging breach of contract and violation of Montana's Unfair Trade Practices Act (UTPA), Mont. Code Ann. 33-18-101 et seq., holding that a sufficient factual basis was established to justify certification of the classes.Plaintiffs filed this action against Fergus Farm Mutual Insurance Company (FFM), alleging that FFM breached its insurance contract with Plaintiffs and all other insureds by failing to include general contractor overhead and profit in the cost to repair or replace Plaintiffs' property. The district court granted Plaintiffs' motion for class certification. The Supreme Court reversed in part, holding (1) the district court did not abuse its discretion by determining that common questions of law predominate the litigation and support certification of the class; but (2) certain conclusions reached by the district court were a "bridge too far" at this stage of litigation. View "Kramer v. Fergus Farm Mutual Insurance Co." on Justia Law
Fox v. The Ritz-Carlton Hotel Company, LLC
Plaintiff, on behalf of himself and individually, filed a class action alleging that the Ritz-Carlton violated the Florida Deceptive and Unfair Trade Practices Act and Florida's tax regulations. Plaintiff's complaint stemmed from allegations that he and others paid illegal automatic gratuities and sales taxes at Ritz-Carlton’s forty-nine restaurants in Florida over the last four years. The district court dismissed the complaint for lack of subject matter jurisdiction based on lack of standing. The district court also dismissed the tax refund claim for lack of subject matter jurisdiction based on plaintiff's failure to exhaust his administrative remedies.The Eleventh Circuit affirmed the dismissal of the tax refund claim based on exhaustion grounds. However, the court held that the district court erred in finding that plaintiff did not have standing to represent the class because he only paid the illegal automatic gratuity at three of Ritz-Carlton's restaurants. The court agreed with plaintiff that the class complaint alleged in good faith that the amount-in-controversy for the hundreds of thousands of Ritz-Carlton guests in Florida that unlawfully paid an automatic gratuity over the last four years exceeded $5 million. Accordingly, the court reversed in part and remanded for further proceedings. View "Fox v. The Ritz-Carlton Hotel Company, LLC" on Justia Law
In re: National Prescription Opiate Litigation
In multi-district litigation (MDL), the district court certified an opt-out “negotiation class” under Federal Rule of Civil Procedure 23, consisting of all cities and counties (34,458 identified entities) throughout the United States for purposes of negotiating a settlement. These municipalities brought RICO and Controlled Substances Act claims, alleging that opioid manufacturers, distributors, pharmacies, and retailers acted in concert to mislead medical professionals into prescribing, and millions of Americans into taking and often becoming addicted to, opiates. Unlike a litigation class, formed to aggregate and try common issues, the negotiation class would attempt to reach a settlement while the individual MDL cases continue on litigation paths. Negotiation class members would likely not have a second opportunity to opt-out and would have to decide at the class certification stage—without knowing the settlement figure— whether they wish to bind themselves. A proposed agreement could only be accepted if a supermajority of six categories of voting class members assent to it.Several defendants objected; 556 putative class members opted-out of the negotiation class. In consolidated appeals, the Sixth Circuit reversed the class certification. Rule 23 does not identify negotiation as a separate category of certification distinct from settlement. The negotiation class device frustrates a court’s analysis of whether a class action is the superior method of adjudication and avoids some of the procedural requirements of litigation class certification without halting the underlying litigation. View "In re: National Prescription Opiate Litigation" on Justia Law