Justia Class Action Opinion Summaries

Defendants Citigroup Inc. and Citibank, N.A. (collectively, “Citi”) appealed from the bankruptcy court’s order granting in part and denying in part Citi’s motion, pursuant to Federal Rule of Bankruptcy Procedure 7012, to dismiss Plaintiff’s amended complaint, or, alternatively, to strike or dismiss the nationwide class action allegations therein. On appeal, Citi advanced s two primary arguments. First, Citi argues that a bankruptcy court’s civil contempt power is limited to the enforcement of its own orders and, therefore, that the Bankruptcy Code does not authorize one bankruptcy court to adjudicate the claims of a nationwide class of former debtors seeking to hold Citi in contempt of discharge orders entered by other bankruptcy courts across the country. Second, Citi argues that Plaintiff’s claim for violation of her discharge order and injunction under 11 U.S.C. Section 524(a)(2) fails to satisfy the civil contempt standard under Taggart v. Lorenzen, 139 S. Ct. 1795 (2019).The Second Circuit affirmed in part and reversed in part the bankruptcy court’s order and remanded the case to the bankruptcy court. The court explained that the Bankruptcy Code does not authorize a bankruptcy court to enforce another bankruptcy court’s discharge injunction. Further, the court wrote that there is no Section 524 “affirmative act” deficiency here. An intentional and systematic refusal to update the credit report upon the debtor’s request constitutes “an act to collect” under Section 524(a)(2), where, objectively, it has the practical effect of improperly coercing the debtor into paying off a discharged debt. View "In re: Kimberly Bruce" on Justia Law

Nicole Woodworth was a registered nurse at Loma Linda University Medical Center (the medical center) from December 2011 to June 2014. In June 2014, she filed this putative class action against the medical center, alleging a host of wage and hour claims on behalf of herself and other employees. She later amended her complaint to add a cause of action under the Private Attorneys General Act of 2004 (PAGA). After several years of litigation, only her individual claim for failure to provide rest periods remained. The trial court had granted four motions for summary judgment in favor of the medical center, denied Woodworth’s motion for class certification, and denied her motion to strike putative class members’ declarations. Woodworth appealed those orders, which disposed of the putative class members’ claims, the PAGA claims, and all of her individual claims (apart from her claim about rest periods). The medical center moved to dismiss most of Woodworth’s appeal, but the Court of Appeal denied the motion, affirming the orders in large part. Specifically, the Court reversed in part the order denying class certification: the court erred with respect to Woodworth’s proposed wage statement class, which consisted of employees who received allegedly inaccurate wage statements. The case was remanded for the trial court to reconsider certification of that class. View "Woodworth v. Loma Linda Univ. Med. Center" on Justia Law

In August 2019, Plaintiff filed a class action against GoDaddy. The putative class alleged that the web-hosting company embarked on an unlawful telemarketing campaign. Objector-Appellant then filed an objection and moved to reconsider the fee award. He made two arguments. First, he objected that the district court awarded fees to class counsel twenty days before the court’s purported objection deadline. Second, he claimed that the parties’ settlement was a “coupon settlement” under 28 U.S.C. Section 1712(e) of the Class Action Fairness Act because GoDaddy class members could select GoDaddy vouchers as their recompense. The question at the core of this appeal is whether the plaintiffs who received a single unwanted, illegal telemarketing text message suffered a concrete injury.   The Eleventh Circuit remanded this appeal to the panel to consider the CAFA issues raised in Appellant’s appeal. The court held that the receipt of an unwanted text message causes a concrete injury. The court explained that while an unwanted text message is insufficiently offensive to satisfy the common law’s elements, Congress has used its lawmaking powers to recognize a lower quantum of injury necessary to bring a claim under the TCPA. As a result, the plaintiffs’ harm “is smaller in degree rather than entirely absent.” View "Susan Drazen, et al v. Mr. Juan Pinto" on Justia Law

This case arose when two companies merged in the biopharmaceutical market. Biopharmaceutical companies develop medicines from living cells. Those medicines must be tested and then approved by the Food and Drug Administration before they can be publicly marketed. The two companies here—INC Research Holdings, Inc. and inVentiv Health, Inc.—did not develop their own medicines, but helped other companies that did. Pre-merger, INC Research specialized in assisting biopharmaceutical companies conduct clinical trials as part of the Food and Drug Administration’s approval process. Wanting to break into the approved-drugcommercialization market, INC Research sought to merge with inVentiv in 2017. Plaintiffs claim that they relied on allegedly misleading statements that INC Research and its executives made in three different communications: (1) the press release announcing the merger; (2) an earnings call held on May 10; and (3) an earnings call held on July 27. The district court dismissed Plaintiffs’ case for failure to state a claim.   The Fourth Circuit affirmed. The court explained that INC Research’s investors have a right to be disappointed that their company’s performance did not meet its optimistic projections. But that does not mean that they also have a right to civil remedies under federal securities law. Securities fraud liability cannot be “predicated solely on an overly optimistic view of a future which may, in fact, encounter harsh economic realities down the road.” View "San Antonio Fire & Police Pension Fund v. Syneos Health Inc." on Justia Law

The Court of Chancery declined to approve a settlement agreement negotiated between Plaintiffs and Defendants on behalf of a class of common stockholders Plaintiffs purported to represent, holding that the proposed settlement was not fair and did not fulfill the principles of due process.Plaintiffs, common stockholders of AMC Entertainment Holdings, Inc., brought direct claims on behalf of a putative class of common stockholders seeking injunctive relief to stop AMC from holding a special meeting at which Plaintiffs, along with holders of fractional units of blank check preferred stock, were scheduled to vote upon two charter amendments that would authorize more common stock triggering the conversion of the fractional units into shares of common stock and reverse a stock split. Before a preliminary injunctive hearing, Plaintiffs negotiated a settlement with Defendants. The Court of Chancery held that the settlement could not be approved as submitted because, among other things, the settlement purported to release claims that did not arise out of the same factual predicate as the claims asserted in this action and because the release of claims arising out of preferred interests was not supported by consideration. View "In re AMC Entertainment Holdings, Inc. Stockholder Litigation" on Justia Law

This is a putative class action by three truck drivers against their employer, Domino’s Pizza. The court previously affirmed the district court’s denial of Domino’s motion to compel arbitration, holding that because the drivers were a “class of workers engaged in foreign or interstate commerce,” their claims were exempted from the Federal Arbitration Act (“FAA”) by 9 U.S.C. Section 1.   The Ninth Circuit affirmed the district court’s order denying Domino Pizza’s motion to compel arbitration in a putative class action brought by three Domino truck drivers, alleging violations of California labor law. The panel stated that its prior decision squarely rested upon its reading of Rittmann v. Amazon.com, Inc., 971 F.3d 904 (9th Cir. 2020), which concerned Amazon delivery drivers. The panel found no clear conflict between Rittmann and Saxon and nothing in Saxon that undermined the panel’s prior reasoning that because the plaintiff drivers in this case, like the Amazon package delivery drivers in Rittmann, transport interstate goods for the last leg to their final destinations, they are engaged in interstate commerce under Section 1. View "EDMOND CARMONA, ET AL V. DOMINO'S PIZZA, LLC" on Justia Law

Plaintiff, on behalf of a putative class of students, sued Southern Methodist University (“SMU”) for refusing to refund tuition and fees after the university switched to remote instruction during the COVID-19 pandemic. The district court dismissed Plaintiff’s complaint for failure to state a claim.   The Fifth Circuit reversed that decision in light of King v. Baylor University, 46 F.4th 344 (5th Cir. 2022), which was issued after the district court’s ruling and which teaches that Hogan adequately pled a breach-of-contract claim. Alternatively, the district court held that Texas’s Pandemic Liability Protection Act (“PLPA”) retroactively bars Plaintiff’s claim for monetary relief and is not unconstitutionally retroactive under the Texas Constitution. That latter ruling raises a determinative-but-unsettled question of state constitutional law, which the court certified to the Texas Supreme Court: Does the application of the Pandemic Liability Protection Act to Plaintiff’s breach-of-contract claim violate the retroactivity clause in article I, section 16 of the Texas Constitution? View "Hogan v. Southern Methodist Univ" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the trial court denying Hoosier Contractors, LLC's motion for summary judgment, denying Sean Gardner's motion for partial summary judgment, and denying Hoosier's motion to decertify a class of Hoosier's similarly situated customers, holding that Gardner, on behalf of himself and as class representative, lacked standing to bring his counterclaim against Hoosier.When Gardner asked Hoosier to inspect the roof of his home Hoosier made Gardner sign a contract for Hoosier to perform any needed work. When Gardner refused to let Hoosier repair his roof Hoosier brought this action for breach of contract. Gardner filed a counterclaim, on behalf of himself and a class of similarly situated customers, alleging that the contract violated the Indiana Home Improvement Contractors Act and that the violations were deceptive acts under the Indiana Deceptive Consumer Sales Act. The Supreme Court held (1) Gardner lacked standing to bring his counterclaim against Hoosier, and this disposition mooted the class-action issues; and (2) the court of appeals properly affirmed the denial of Gardner's motion for partial summary judgment as to Hoosier's breach of contract claim. View "Hoosier Contractors, LLC v. Gardner" on Justia Law

Marvin and Mildred Bay (“the Bays”) challenged a court order dismissing their trespass claim against Anadarko E&P Onshore LLC and Anadarko Land Corporation (collectively, “Anadarko”). Anadarko, an oil and gas company, owned the mineral rights under the Bays’ farm. The Bays brought a putative class action along with other surface landowners against Anadarko, alleging that Anadarko’s mineral lessees had exceeded the scope of their mineral rights by drilling multiple vertical wells on the surface owners’ land when it was possible to drill fewer wells of the “directional” type. At the conclusion of the Bays’ presentation of evidence, the district court found that the Bays’ evidence failed as a matter of law to demonstrate that Anadarko’s activities amounted to a trespass and dismissed the case. Finding that the district court applied the wrong legal standard, the Tenth Circuit reversed the dismissal in "Bay I," finding that Colorado’s common law of trespass required the Bays to show that Anadarko’s lessees had “materially interfered” with the Bays’ farming operations. The appellate court questioned whether the record demonstrated that the Bays met this standard in their trial, but because Anadarko had not raised this specific issue, the case was remanded to the district court for further proceedings. On remand, the district court again granted judgment as a matter of law to Anadarko on the material interference issue. Specifically, the court first held that it was bound by the Tenth Circuit's interpretation in Bay I of the material interference standard, then found that the Bays showed only that Anadarko’s conduct inconvenienced them—which was insufficient to satisfy the material interference standard. The Bays again appealed, arguing that the Tenth Circuit's discussion of the material interference standard in Bay I was dictum; thus, the district court incorrectly determined that it was bound to apply that standard. They further argued the material interference standard applied by the district court was inconsistent with the Colorado standard for trespass outlined in Gerrity Oil & Gas Corp. v. Magness, 946 P.2d 913 (Colo. 1997), and that the evidence they presented in their trial established a prima facie case of material interference under Gerrity. The Tenth Circuit determined the district court did not err in its second dismissal and affirmed judgment. View "Bay, et al. v. Anadarko E&P Onshore, et al." on Justia Law

Appellees worked as non-emergency medical transportation drivers. In July 2017, they brought a putative class action and Fair Labor Standards Act collective action against Medical Transportation Management, Inc. (“MTM”). Their complaint alleged that MTM is their employer and had failed to pay them and its other drivers their full wages as required by both federal and District of Columbia law. MTM appealed the district court’s certification of an “issue class” under Federal Rule of Civil Procedure 23(c)(4) and its denial of MTM’s motion to decertify plaintiffs’ Fair Labor Standards Act collective action.   The DC Circuit remanded the district court’s certification of the issue class because the court failed to ensure that it satisfies the class-action criteria specified in Rules 23(a) and (b). The court declined to exercise pendent appellate jurisdiction to review the district court’s separate decision on the Fair Labor Standards Act collective action. The court explained that because the resolution of the action will bind absent class members, basic principles of due process require that they be notified that their individual claims are being resolved and that they may opt out of the action if they so choose. So if the district court certifies the issue class under Rule 23(b)(3) on remand, it must direct “the best notice that is practicable” as part of any certification order. View "Isaac Harris v. Medical Transportation Management, Inc." on Justia Law