Justia Class Action Opinion Summaries

A former hourly employee brought a class action lawsuit against his former employer, a large wood products company, alleging various wage and hour violations under California law. The proposed classes included both employees who had signed arbitration agreements and those who had not. While some nonexempt employees had signed arbitration agreements requiring individual arbitration and waiving class actions, the named plaintiffs had not. The employer did not initially assert arbitration as a defense and, when ordered by the court to produce copies of signed arbitration agreements for putative class members, failed to do so for several years.During the course of discovery in the Superior Court of Shasta County, the employer repeatedly resisted requests to identify or produce arbitration agreements for employees who had signed them, leading to multiple discovery sanctions. The employer participated in extensive discovery and mediation involving employees who had signed arbitration agreements, without distinguishing them from other putative class members. Only after class certification did the employer finally produce thousands of signed arbitration agreements and immediately moved to compel arbitration for those employees. Plaintiffs opposed, arguing the employer had waived its right to arbitrate by years of litigation conduct inconsistent with an intent to arbitrate, and sought evidentiary and issue sanctions for delayed production.The California Court of Appeal, Third Appellate District, reviewed the case. Applying the California Supreme Court’s standard from Quach v. California Commerce Club, Inc., the appellate court held that the employer waived its right to compel arbitration by clear and convincing evidence. The employer’s prolonged failure to produce arbitration agreements and its conduct throughout litigation was inconsistent with an intention to enforce arbitration. The order denying the motion to compel arbitration was affirmed, and the appeal from the order granting evidentiary and issue sanctions was dismissed as nonappealable. View "Sierra Pacific Industries Wage and Hour Cases" on Justia Law

Several parents of disabled children brought a class action against the New York City Department of Education, the Board of Education of the City School District of New York, and the Chancellor, alleging that the defendants violated the Individuals with Disabilities Education Act (IDEA). The plaintiffs claimed the defendants maintained a policy of discontinuing special education services to disabled students before their twenty-second birthday, despite federal and state guidance and previous case law indicating that such services should continue until that age.The United States District Court for the Southern District of New York dismissed the suit, finding that it lacked subject-matter jurisdiction because the plaintiffs had not exhausted administrative remedies as generally required under the IDEA. The district court agreed with the defendants’ argument that exhaustion was necessary and rejected the plaintiffs’ contention that exhaustion would be futile due to the existence of a blanket, citywide policy.On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s dismissal. The appellate court clarified that the IDEA’s exhaustion requirement is not jurisdictional but is instead a claim-processing rule, meaning that failure to exhaust is not a bar to the court’s power to hear the case. The Second Circuit held that exhaustion of administrative remedies is excused when plaintiffs challenge a policy or practice of general applicability that is contrary to law and when the purposes of exhaustion—such as developing a factual record or utilizing agency expertise—would not be served. Because the plaintiffs’ claims raised a purely legal question regarding the validity of a blanket policy, the court found that exhaustion would be futile. The Second Circuit vacated the district court’s dismissal and remanded the case for further proceedings. View "J.M. v. New York City Dept. of Ed." on Justia Law

A company that provides temporary labor to various industries offers daily work opportunities to individuals at its labor halls. Workers can choose whether to accept job assignments, and once they do, they are responsible for arriving at the jobsite on time. The company offers several transportation options—including vans, carpools, and public transit—with a nominal fee deducted from paychecks for those who use company-arranged transportation. Workers can also bring their own tools or use company-provided equipment, with deductions only made for unreturned items.A group of workers filed a class action in the United States District Court for the Southern District of Florida, alleging violations of the Fair Labor Standards Act (FLSA) and the Florida Minimum Wage Act. They claimed that transportation deductions reduced their pay below the minimum wage and that the company failed to pay for travel time, time spent collecting tools, and waiting time. The plaintiffs also raised a claim under the Florida Labor Pool Act regarding excessive transportation charges. The district court granted summary judgment to the company on the FLSA and minimum wage claims, denied the plaintiffs’ summary judgment motion, and declined to certify the subclass related to excessive transportation charges.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the transportation deductions were lawful because the transportation was optional and for the benefit of employees, not the employer. The court further held that time spent traveling, collecting tools, and waiting was not integral and indispensable to the workers’ principal activities and was thus noncompensable under the FLSA. Finally, the court affirmed the district court’s denial of class certification for the excessive-transportation-charge subclass, finding that individual inquiries would predominate. The judgment of the district court was affirmed. View "Villarino v. Pacesetter Personnel Service, Inc." on Justia Law

The case concerns challenges to groundwater replenishment charges imposed by a water district in a desert region where groundwater is the main source of potable water. The water district operates three areas of benefit (AOBs) and levies replenishment charges on customers who pump significant groundwater. Domestic customers do not pay these charges directly, but their payments for drinking water are allocated to the replenishment funds through the district’s enterprise fund system. Plaintiffs, including a taxpayer association, alleged that the replenishment charges were unconstitutionally structured, resulting in higher rates for certain AOBs and unfair subsidies for others, benefitting large agricultural businesses.The litigation began with a combined petition and class action in the Superior Court of Riverside County, which was dismissed because the court found the validation statutes applied and the statute of limitations had expired. Subsequent reverse validation actions for later fiscal years were timely filed and consolidated. The Superior Court, in rulings by two judges, found the replenishment charges to be unconstitutional taxes because they did not satisfy the requirements of California Constitution Article XIII C, Section 1, subdivision (e)(2). Specifically, the court found that the district failed to show the allocation of replenishment costs bore a fair or reasonable relationship to the burdens or benefits received by each AOB, and thus the charges were not exempt from being classified as taxes. The court awarded substantial refunds to affected ratepayers and enjoined the district from imposing similar unconstitutional charges in the future.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed both the district’s appeal of the remedies and liability findings and the taxpayer association’s cross-appeal on procedural grounds. The appellate court affirmed in full, holding that the replenishment charges were unconstitutional, the remedies were proper, and that the validation statutes applied to these charges, thus barring untimely claims for earlier years. The appellate court also found no error in the trial court’s grant of refund and injunctive relief. View "Howard Jarvis Taxpayers Assn. v. Coachella Valley Water Dist." on Justia Law

A Missouri consumer purchased several containers of coffee that prominently displayed the number of servings each container could make. He claimed these representations were misleading, arguing that following the recommended single-serving brewing method would not produce as many servings as advertised. He filed a lawsuit against the coffee manufacturer and its parent company, alleging violations of the Missouri Merchandising Practices Act (MMPA) and unjust enrichment. The plaintiff sought to represent a class of Missouri consumers who purchased the same products.Multiple similar lawsuits from around the country were consolidated in the United States District Court for the Western District of Missouri. The district court appointed interim class counsel and, at the parties’ suggestion, considered whether to certify a Missouri class before addressing other states. The district court ultimately certified the Missouri class, finding that the plaintiff’s claims were suitable for class treatment under Federal Rule of Civil Procedure 23(b)(3), which requires that common questions predominate over individual ones.On appeal, the United States Court of Appeals for the Eighth Circuit held that the district court erred in certifying the class. The appellate court determined that individual questions about whether consumers saw, interpreted, or relied upon the product representations would predominate over common questions. The court rejected the plaintiff’s argument that all class members suffered harm due to alleged price inflation, reasoning that only those who were actually misled or cared about the representations could have incurred an ascertainable loss under the MMPA. The court also found the unjust enrichment claim similarly unsuited to class treatment because it would require individualized inquiries into whether each transaction was unjust. The Eighth Circuit reversed the class certification order and remanded the case for further proceedings. View "Sorin v. The Folger Coffee Company" on Justia Law

A freight train operated by Norfolk Southern derailed in East Palestine, Ohio, in early 2023, releasing hazardous materials and causing widespread evacuations and concern over health, environmental, and economic impacts. Numerous lawsuits were filed by affected individuals and businesses, which were consolidated into a master class action. The parties reached a $600 million settlement, which included provisions for a settlement fund and attorney’s fees. The district court approved the settlement and the attorney’s fees request, designating co-lead counsel to allocate fees among the plaintiffs’ attorneys, including Morgan & Morgan, a firm representing some individual claimants.After the district court in the United States District Court for the Northern District of Ohio approved the settlement and fee awards, Morgan & Morgan, despite having received nearly $8 million in fees, objected to the process and timing of fee allocation, specifically challenging the settlement’s “quick pay” provision and the authority given to co-lead class counsel to distribute fees. Morgan & Morgan also raised concerns about transparency and the adequacy of its own fee award, arguing that the allocation process might have undervalued its contributions.On appeal, the United States Court of Appeals for the Sixth Circuit held that Morgan & Morgan lacked standing to challenge the quick pay provision, as it did not suffer a concrete, particularized injury from the timing of payment and had assented to the settlement terms. The court also affirmed the district court’s decision to delegate initial fee allocation authority to co-lead class counsel, finding no abuse of discretion and noting the court retained jurisdiction for oversight. However, the Sixth Circuit found the district court had failed to address Morgan & Morgan’s specific concerns about its fee allocation and remanded that narrow issue for further consideration. The judgment was thus affirmed in part, reversed in part, and remanded. View "In re E. Palestine Train Derailment" on Justia Law

Several former employees brought a class action lawsuit against their previous employer, a fast-food chain, challenging three company policies: excessive wage deductions for the Oregon Workers’ Benefit Fund (WBF), failure to pay for interrupted meal breaks longer than 20 minutes, and deductions for non-slip shoes required for work. The WBF overdeductions occurred when the employer failed to adjust employee contribution rates as the state rate decreased, causing employees to pay more than their share. The company also required employees to purchase specific non-slip shoes, from which it received vendor rebates, and allowed the cost to be deducted from wages.In the United States District Court for the District of Oregon, the plaintiffs prevailed on the WBF claims, with the court finding at summary judgment that the WBF overdeductions were willful, and that shoe deductions were for the plaintiffs’ benefit, leaving for trial whether the shoes were authorized in writing. The jury awarded substantial penalty wages for the WBF overdeductions, but the district court later reduced the jury’s award relating to shoe deductions, holding that written authorization was a defense. The court also denied class certification for the unpaid break claims, finding individual inquiry necessary, and refused to exclude class members who did not receive mailed notice or to reduce prejudgment interest for alleged plaintiff delay.On appeal, the United States Court of Appeals for the Ninth Circuit reversed in part and affirmed in part. The court held that the district court erred in granting summary judgment on willfulness regarding the WBF overdeductions and on whether the shoe deductions were for the employees’ benefit, requiring both issues be retried by a jury. The appellate court also clarified that written authorization was not a defense to minimum wage and overtime violations relating to shoe deductions. The court affirmed the district court’s judgment on the unpaid break claims and on notice and prejudgment interest issues. The case was remanded for further proceedings consistent with these holdings. View "GESSELE V. JACK IN THE BOX INC." on Justia Law

A consumer purchased a used vehicle from a dealership, with the transaction documented in two contracts: a purchase order and a retail installment sale contract (RISC). The purchase order included an arbitration provision for disputes arising from the purchase or financing of the vehicle, while the RISC detailed the financing terms but did not include an arbitration clause. The RISC contained an assignment clause by which the dealership assigned its interest in "this contract" (the RISC) to a third-party lender, and defined the agreement between the buyer and the assignee as consisting "only" of the RISC and any addenda. The consumer later filed a class action against the lender, alleging improper fees under Maryland law.The Circuit Court for Baltimore City found for the lender, ruling that the purchase order and RISC should be read together as one contract for the purposes of the transaction, and that the arbitration agreement was enforceable against the consumer. The court granted the lender’s motion to compel arbitration. On appeal, the Appellate Court of Maryland affirmed, holding that the consumer was bound by the arbitration provision and that the assignee lender could enforce it, even though the consumer did not receive or sign a separate arbitration agreement.The Supreme Court of Maryland reviewed the case, focusing on contract interpretation and the scope of the assignment. The court held that, even if the purchase order’s arbitration provision was binding between the consumer and the dealer, it was not within the scope of the assignment to the lender. The RISC’s assignment language made clear that only the RISC and its addenda, not the purchase order or its arbitration clause, were assigned to the lender. As a result, the Supreme Court of Maryland reversed the judgment of the Appellate Court and remanded the case for further proceedings. View "Lyles v. Santander Consumer USA" on Justia Law

A consumer brought a lawsuit against a national retail pharmacy chain after receiving electronically printed receipts that displayed the first six and last four digits of her prepaid debit card number when she added funds to her card at one of the chain’s stores. She alleged that the retailer willfully violated the Fair and Accurate Credit Transactions Act (FACTA) by printing more than the last five digits of her card number, and she claimed this exposed her to a heightened risk of identity theft and invasion of her privacy. The consumer sought to represent a nationwide class of similarly situated individuals and requested statutory damages, punitive damages, attorney fees, and costs.The case began in the Circuit Court of Lake County, Illinois, where the retailer moved to dismiss, arguing that the consumer lacked standing because she had not alleged an actual injury and was merely a “no-injury” plaintiff. The circuit court denied the motion, reasoning that a statutory violation alone was sufficient for standing under Illinois law, and subsequently granted the plaintiff’s motion for class certification, with some modifications to the class definition. The retailer petitioned for leave to appeal this certification order. The Appellate Court of Illinois affirmed the circuit court’s decision, holding that the plaintiff had standing based on the three-part test for standing under Illinois law and finding that the violation of FACTA constituted a distinct and palpable injury, fairly traceable to the retailer’s conduct, and capable of being redressed by the requested relief.On further appeal, the Supreme Court of the State of Illinois reversed both the appellate and circuit courts. The supreme court held that the plaintiff lacked standing because she failed to allege a concrete injury—her asserted risk of future identity theft was deemed too speculative. The court concluded that, without such an injury, the plaintiff could not maintain her individual or class claims under FACTA, and directed the circuit court to dismiss the case for lack of standing. View "Fausett v. Walgreen Co." on Justia Law

Residents of Jackson, Mississippi, brought a class action lawsuit alleging that the city knowingly contaminated their drinking water with lead, failed to treat the water to prevent lead leaching, and misled the public about the water’s safety. The complaint details how city officials ignored warnings about the water system’s vulnerabilities, failed to repair critical treatment equipment, switched water sources in a way that worsened contamination, and delayed notifying residents of dangerous lead levels. Plaintiffs claim they and their families suffered significant health effects, including lead poisoning and related medical and developmental issues, as a result of consuming the contaminated water.The United States District Court for the Southern District of Mississippi granted the defendants’ motion for judgment on the pleadings. The court found that the plaintiffs failed to state a substantive due process claim against the city and that the individual city officials were entitled to qualified immunity. The district court also declined to exercise supplemental jurisdiction over the state-law claims, dismissing them without prejudice.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The Fifth Circuit held that the plaintiffs plausibly alleged a violation of their Fourteenth Amendment right to bodily integrity by claiming the city affirmatively introduced toxins into the water supply, misrepresented the water’s safety, and thereby deprived residents of the ability to make informed decisions about their health. The court also formally adopted the state-created danger doctrine as a viable theory in the circuit. The court reversed the dismissal of the due process claims against the city and vacated the dismissal of the state-law claims, remanding for further proceedings. However, the court affirmed the dismissal of claims against the individual city officials on qualified immunity grounds, finding the relevant rights were not clearly established at the time. View "Sterling v. City of Jackson" on Justia Law