Justia Class Action Opinion Summaries

Plaintiffs, nine children in the custody of PMC, filed suit under 42 U.S.C. 1983 against three Texas officials, in their official capacities, seeking to represent a class of all children who were now, and all those who will be, in the State's long-term foster care. The gravaman of plaintiffs' complaint is that various system-wide problems in Texas's administration of its PMC subjected all of the children in PMC to a variety of harms. Applying the standards announced in the Supreme Court's recent opinion, Wal-mart Stores, Inc. v. Dukes, the court held that the district court failed to conduct the "rigorous" analysis required by Rule 23 in deciding to certify the proposed class. The court also held that the district court abused its discretion by certifying a class that lacked cohesiveness under Rule 23(b)(2). Accordingly, the court vacated the district court's class certification order and remanded for further proceedings. View "M.D., et al. v. Rick Perry, et al." on Justia Law

Plaintiffs, three plaintiff-classes and Sheila Perdue individually, brought a class action complaint seeking declaratory and injunction relief alleging violations of their federal statutory and constitutional rights. Plaintiffs challenged the Indiana Family and Social Services Administration's (FSSA) automated system of processing claims for Medicaid, Food Stamps, and Temporary Assistance to Needy Families benefits. The trial court held (1) the FSSA's denial notices satisfied due process; (2) the FSSA could not deny an application for Food Stamp benefits when the applicant failed to cooperate in the eligibility determination process; and (3) determined that the FSSA had failed to accommodate Perdue's disabilities in violation of the Americans with Disabilities Act and the Rehabilitation Act. The Supreme Court reversed in part and affirmed in part, holding (1) the FSSA's denial notices were insufficiently explanatory in violation of due process; (2) the FSSA may deny an application for Food Stamp benefit when the applicant fails to cooperate in the eligibility determination process; and (3) Perdue was entitled to reasonable accommodations in applying for benefits, but that did not necessarily require providing a caseworker or case management services. View "Perdue v. Gargano" on Justia Law

Plaintiff filed a putative class action against M&T Bank, alleging that it improperly charged its checking account customers overdraft fees. The district court denied M&T Bank's renewed motion to compel arbitration, finding that plaintiff's claims were not within the scope of the parties' arbitration agreement. The court held that, under the delegation provision, the decision of whether plaintiff's claims were within the scope of the arbitration agreement was a decision for an arbitrator, and the district court erred in making the decision itself. Further, the court believed that it was prudent for the district court to reconsider its unconscionability determination in light of AT&T Mobility LLC v. Conception, so the court did not reach whether the arbitration agreement was unconscionable. Accordingly, the court vacated and remanded. View "Given v. M&T Bank Corp, et al." on Justia Law

This consolidated appeal arose out of an alleged multi-billion dollar Ponzi scheme perpetrated by R. Allen Stanford through his various corporate entities. These three cases dealt with the scope of the preclusion provision of the Securities Litigation Uniform Standards Act (SLUSA), 15 U.S.C. 78bb(f)(1)(A). All three cases sought to use state class-action devices to attempt to recover damages for losses resulting from the Ponzi scheme. Because the court found that the purchase or sale of securities (or representations about the purchase or sale of securities), was only tangentially related to the fraudulent scheme alleged by appellants, the court held that SLUSA did not preclude appellants from using state class actions to pursue their recovery and reversed the judgment. View "Roland, et al. v. Green, et al.; Troice, et al. v. Proskauer Rose, LLP, et al.; Troice, et al. v. Willis of Colorado Inc., et al." on Justia Law

In these consolidated appeals, Carol Perdue, individually and as next friend and guardian of her daughter, Anna; William D. Motlow, Jr.; and Shane Sears (hereinafter collectively referred to as "the objectors"), all of whom were objecting class members in class-action litigation related to the Alabama Prepaid Affordable College Tuition ("PACT") Trust Fund a/k/a The Wallace-Folsom Prepaid College Tuition Trust Fund, appealed the trial court's judgment that approved a class-action settlement concluding the litigation. The objectors largely complained that as contributors or beneficiaries of the PACT fund, it was being mismanaged and underfunded to their detriment. While the case was pending, the Alabama Legislature changed the laws directly impacting the management and funding of the PACT program. The PACT Board responded to the change in the law by moving to dismiss the objectors' suit as moot. The issues on appeal before the Supreme Court involved terms of the settlement agreement: the objectors contended that the trial court permitted language in the agreement that ran afoul of the changed laws and disregarded objections of the complaining members of the class. Upon review, the Supreme Court vacated the trial court's judgment and remanded the case: "[t]he scope of the objections in the trial court was not the narrow question whether the order should bind only the objectors, but, on the contrary, the issue presented [was] the broader question whether the trial court's judgment approving the settlement agreement [was] due to be affirmed. . . . the objectors are allowed to appeal that aspect of the trial court's order that affects them - 'the [circuit court's] decision to disregard [their] objections.' If the judgment [was] affirmed, the settlement agreement affects them in that it binds them, as members of the class, to terms of a settlement agreement inconsistent with 16-33C-19." View "Perdue v. Green" on Justia Law

Plaintiffs, current and former customers of AT&T, filed a class action against AT&T, alleging unjust enrichment and and breach of contract. AT&T responded by seeking to enforce an arbitration agreement contained in its contracts with plaintiffs. The district court refused to enforce the arbitration agreement on state-law unconscionability grounds, relying primarily on the agreement's class-action waiver provision. The court reversed the district court's substantive unconscionability ruling where the FAA preempted the Washington state law invalidating the class-action waiver. The court remanded for further proceedings related to plaintiffs' procedural unconscionability claims for the district court to apply Washington choice-of-law rules. View "Coneff, et al. v. AT&T Corp, et al." on Justia Law

Plaintiff Bruce Roger Mills, individually and on behalf of those similarly situated, appealed a judgment that dismissed his claims against the City of Grand Forks to recover the amount of fines and fees collected in the past for noncriminal traffic violations by the City exceeding the amount the City could legally impose under state law. The City cross-appealed that judgment. In 2004, a Grand Forks police officer cited Plaintiff with careless driving. Under Grand Forks City Code, the maximum fine for violation of a noncriminal offense was $1,000 "in the discretion of the court." Plaintiff pled not guilty and proceeded to trial in municipal court. Plaintiff was found guilty. The municipal court imposed against Plaintiff "a fine in the amount of $151 with $0 suspended" and a hearing fee of $15. Plaintiff appealed to district court for a new trial; the court affirmed the conviction and the fine and fees totaling $166. Plaintiff appealed to the Supreme Court, but on December 1, 2004, the Court dismissed the appeal because the district court judgment was "not appealable under N.D.C.C. 39-06.1-03(5)." On August 16, 2010, Plaintiff brought a "Class Action Complaint for Restitution" in state district court seeking the amount of monies paid to Grand Forks exceeding the state law limits for fines for similar state offenses. Plaintiff asserted the excess fines, fees and charges were "involuntary and void." The City argued Plaintiff's claims were precluded by both res judicata and collateral estoppel based on the prior federal court action, and by res judicata because Mills failed to challenge the City's fine scheme in the 2004 state court proceedings. Because the district court correctly ruled Plaintiff's claims were thus barred by res judicata, the Supreme Court affirmed the judgment. View "Mills v. City of Grand Forks" on Justia Law

This case arose when plaintiffs filed a class action complaint under 42 U.S.C. 1983, alleging that the District was violating the Medicaid Act, 42 U.S.C. 1396 et seq. Since 1993, a consent decree has governed how the District provides "early and periodic screening, diagnostic, and treatment services" under the Act. The District has now asked the district court to vacate that decree on two grounds: that an intervening Supreme Court decision has made clear that plaintiffs lack a private right of action to enforce the Medicaid Act, and that in any event, the District has come into compliance with the requirements of the Act. Because the court concluded that the district court's rejection of one of the District's two arguments did not constitute an order "refusing to dissolve [an] injunction[]" within the meaning 28 U.S.C. 1292(a)(1), the court dismissed the appeal for lack of jurisdiction. View "Salazar, et al. v. DC, et al." on Justia Law

As a consequence of a June 2006 storm, the stormwater drainage and storage system (including the wastewater treatment facility) at the Lake Charles refinery of Defendant CITGO Petroleum Company (CITGO), was filled beyond available capacity and overflowed, resulting in a major oil spill. Over 21 million gallons of waste, including 17 million gallons of contaminated wastewater and 4.2 million gallons of slop oil, escaped from the two existing wastewater storage tanks into an area around the tanks which was surrounded by levees or dikes. The oil spill, which was described at trial as "major" and "catastrophic," eventually contaminated over 100 miles of shoreline along the Calcasieu River, and required several months to clean up. Fourteen plaintiffs, employees of Ron Williams Construction (RWC) working at the Calcasieu Refining Company (CRC) south of the CITGO refinery, filed suit against CITGO and R&R Construction, Inc. (R&R) alleging various injuries due to their exposure to noxious gases emanating from the spill. CITGO and R&R stipulated that they were liable for the spill and agreed to pay plaintiffs for all their compensatory damages assessed to CITGO and R&R. After a two week bench trial, the district court ruled that plaintiffs had proved their injuries were caused by CITGO's admitted negligence in allowing the spill. The court of appeal affirmed, holding that the district court's finding the spill caused plaintiffs' injuries was not an abuse of discretion. The Supreme Court granted review of this case to determine whether the courts below erred as to the allocation of fault, in awarding damages for fear of future injury, and in awarding punitive damages. In sum, the Court held that Louisiana's conflict of laws statutes did not provide for the application of the punitive damages laws of Texas or Oklahoma under the facts of this case, that plaintiffs proved that their damages were caused by their exposure to toxic chemicals contained in the oil spill, that plaintiffs are entitled to damages for fear of contracting cancer, and that CITGO did not produce at the hearing on summary judgment factual support sufficient to establish that it would be able to satisfy its evidentiary burden of proof at trial. The Court affirmed in part, and reversed in part. The case was remanded for further proceedings. View "Arabie v. CITGO Petroleum Corp." on Justia Law

Defendant William Coleman was serving a fifteen-year sentence following his convictions on charges pertaining to his relationship with his ex-wife when he went on a hunger strike. Following a trial, the trial court granted the former commissioner of correction's application for a permanent injunction authorizing the department of correction to restrain and force-feed Defendant to prevent life-threatening dehydration and malnutrition. Defendant was subsequently force-fed. The Supreme Court affirmed, holding that the trial court properly determined (1) the state's interests outweighed Defendant's common-law right to bodily integrity; (2) the forcible administration of artificial nutrition and hydration to Defendant did not violate his constitutional right to free speech and privacy; and (3) international law did not prohibit medically necessary force-feeding under such circumstances. View "Comm'r of Corr. v. Coleman" on Justia Law