Justia Class Action Opinion Summaries

A resident of St. Louis brought a class action lawsuit against the city, seeking a refund of fees paid for solid waste services. The plaintiff alleged that these fees were collected under the mistaken belief that the city was providing separate recycling and yard waste collection, which the city either failed to provide or did not provide consistently. The city had implemented a monthly solid waste services fee in 2010, increased it in 2017, and included the fee in residents’ water bills. Although the city at times collected recyclables and yard waste separately, it often did not, and ultimately terminated the program in 2025. The plaintiff argued that the city unjustly retained fees for services it did not render, seeking damages for herself and other residents.The Circuit Court of the City of St. Louis denied the city’s motion to dismiss, finding that the plaintiff’s claim for “money had and received” could proceed. The city then sought a writ of prohibition from the Missouri Court of Appeals, which was denied. The city subsequently sought relief from the Supreme Court of Missouri.The Supreme Court of Missouri held that the city is protected by sovereign immunity and that section 432.070 of the Missouri Revised Statutes bars the claim. The court found that the plaintiff’s allegations did not plead facts that would establish an exception to sovereign immunity for her claim and that no statutory or recognized common law exception applied. The court also concluded that the proprietary function exception did not apply, as solid waste collection is a governmental function. The court made its preliminary writ of prohibition permanent, directing that the plaintiff’s claim be dismissed. View "State ex rel. City of St. Louis vs. Whyte" on Justia Law

Technicians employed by the defendant performed installation, maintenance, inspection, testing, repair, and replacement of fire alarms, fire sprinklers, and security system equipment under contracts with public entities in New York. These contracts varied in their language regarding the payment of prevailing wages: some disclaimed any obligation to pay prevailing wages, some were silent, and a few expressly based payment on prevailing wage rates. All contracts included a clause providing that any action against the defendant had to be brought within one year of accrual.The plaintiffs brought a proposed class action in the United States District Court for the Northern District of New York, alleging, among other claims, that they were owed prevailing wages as third-party beneficiaries of the contracts. The District Court granted the defendant’s motion for partial summary judgment, finding that the breach of contract claims were time-barred by the contractual limitation period, that the contracts did not expressly entitle plaintiffs to prevailing wages, and, in the alternative, that plaintiffs were not covered by the prevailing wage law. On appeal, the United States Court of Appeals for the Second Circuit held that plaintiffs were covered by Labor Law § 220 but certified two questions to the New York Court of Appeals regarding the implicit inclusion of prevailing wage promises in public works contracts and the enforceability of shortened contractual limitation periods.The New York Court of Appeals held that the promise to pay prevailing wages is implicit in every public works contract covered by Labor Law § 220, regardless of whether that promise appears in the contract’s text. As a result, employees may bring third-party beneficiary breach of contract claims to enforce the prevailing wage requirement. The Court further held that contractual agreements to shorten the statute of limitations for such claims are unenforceable. The Court answered the first certified question in the affirmative and the second in the negative. View "Walton v Comfort Sys. USA (Syracuse), Inc." on Justia Law

Robert Cocom, a former airport janitor, brought a putative class action against his previous employer, ABM Aviation, Inc., alleging wage and hour violations. When he was hired, Cocom signed a Mutual Arbitration Agreement (MAA) requiring employment-related disputes to be resolved through arbitration. The MAA included waivers of class, collective, and representative actions, as well as a provision stating that arbitration awards would not have preclusive or precedential effect in other proceedings. Cocom’s lawsuit was originally filed in state court but was removed to federal court by ABM, which then moved to compel arbitration and strike the class claims.The United States District Court for the Central District of California denied ABM’s motion, finding the arbitration agreement both procedurally and substantively unconscionable. The court relied heavily on the California Court of Appeal’s decision in Cook v. University of Southern California, interpreting the MAA as having an overly broad scope, indefinite duration, and lack of mutuality, and concluding that certain waivers violated California law. Finding multiple provisions unconscionable, the district court declined to sever them and refused to enforce the MAA.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s judgment. The appellate court held that the MAA’s provisions were distinguishable from those in Cook, noting that the MAA was limited to employment-related disputes, thereby avoiding the overbreadth, indefinite duration, and mutuality issues identified in Cook. The Ninth Circuit also found that any potentially unconscionable waivers (such as those related to representative actions or public injunctive relief) were severable. The main holding was that the MAA was not substantively unconscionable and should be enforced, and the case was remanded for further proceedings. View "COCOM V. ABM AVIATION, INC." on Justia Law

A utility company, Southern California Gas (SoCalGas), entered into a 2022 franchise agreement with the City of Los Angeles, allowing it to install, maintain, and operate its natural gas system under city streets. In exchange, SoCalGas agreed to pay the City a franchise fee equal to 5.5% of its gross receipts from natural gas sales within the City. Of this, 3.5% was passed to SoCalGas customers as a surcharge, which was later approved by the California Public Utilities Commission (CPUC). The franchise agreement was adopted after extensive, arm’s-length negotiations and CPUC review.A putative class action was filed by a customer, alleging that the surcharge component of the franchise fee constituted an unlawful tax under article XIII C of the California Constitution because it was not submitted for voter approval. The plaintiff argued the fee should have been apportioned between charges for physical use of city property and charges for the general business privilege, with the latter portion requiring voter approval. The Superior Court for Los Angeles County granted summary judgment for the City, finding the franchise fee, including the surcharge, exempt from voter approval as a charge for the use of local government property under section 1, subdivision (e)(4) of article XIII C.The California Court of Appeal, Second Appellate District, affirmed the trial court’s judgment. The Court held that the franchise fee, including the portion passed through as a surcharge, was not a tax within the meaning of article XIII C, section 1, subdivision (e)(4), because it was compensation for the use of city property and not subject to voter approval. The Court further held that the fee did not need to be apportioned or shown to be reasonably related to the value of the franchise, but found that, even if such a requirement existed, the City met it through bona fide negotiations. View "Nguyen v. City of L.A." on Justia Law

Two individuals filed a lawsuit on behalf of themselves and a proposed class, alleging that a life insurance company’s “Trendsetter LB” term life insurance policy misrepresented its premium structure. The plaintiffs argued that policy language stating the annual premium was “excluding riders” and that additional accelerated death benefit riders were included at “no charge” was misleading. They claimed consumers were led to believe these extra benefits were free, when in fact the premium included undisclosed charges for these riders. The plaintiffs did not allege they were denied any promised benefits, but contended the policy failed to break down the cost of its bundled components, allegedly causing consumers to misunderstand their options and overpay compared to a more basic policy.The case began in Alameda County Superior Court. Plaintiffs sought class certification for claims under California’s Unfair Competition Law (UCL), focusing only on alleged misrepresentations in the policy’s standardized language. The trial court initially found ascertainability and numerosity met, but denied class certification for most claims, ruling that determining liability would require individualized inquiries into what information each customer received from agents or marketing materials. The court certified only a narrow claim regarding compliance with a statutory notice requirement, but later, at plaintiffs’ request, denied certification entirely when they clarified they did not intend to pursue that claim.The Court of Appeal of the State of California, First Appellate District, Division One, affirmed the trial court’s denial of class certification. The court held that the policy language was, at best, ambiguous and that resolving liability would depend not just on the form policy language but also on individualized evidence about communications with each purchaser. The court determined that common issues did not predominate and that the trial court did not abuse its discretion in denying certification. The judgment was affirmed. View "Guthrie v. Transamerica Life Ins. Co." on Justia Law

Employees participating in a 401(k) plan offered by their employer, a clinical laboratory company, brought a class action alleging that the plan’s fiduciaries breached their duties under ERISA by retaining two particular investment options: the Fidelity Freedom Funds and the Invesco Global Real Estate Fund. The plaintiffs argued that these funds underperformed compared to alternatives, were riskier, and that the plan’s managers failed to remove them despite subpar performance. They also claimed that internal policy statements required the funds’ removal and that the plan’s managers failed in their duty to monitor investments and breached trust obligations.The United States District Court for the District of New Jersey initially denied a motion to dismiss the case, allowing discovery to proceed. After discovery, the District Court granted summary judgment in favor of the defendants. The court found that the plan’s fiduciaries had fulfilled their obligations by hiring investment advisors, regularly reviewing investment performance, seeking relevant training, and following up on concerns regarding the challenged funds. The court concluded there was no breach of fiduciary duty or related failures.On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s grant of summary judgment de novo, considering all facts and inferences in favor of the plaintiffs. The Third Circuit held that ERISA’s fiduciary standard is process-oriented, not outcome-based. The Court found that the fiduciaries had used a prudent process—hiring advisors, critically assessing their recommendations, meeting with fund managers, and maintaining regular oversight—even if the investments did not always outperform alternatives. The Court further held that internal policy statements were nonbinding and that the fiduciaries did not abuse their discretion. Consequently, the Third Circuit affirmed the District Court’s summary judgment in favor of the defendants on all claims. View "Johnson v. Quest Diagnostics Inc" on Justia Law

Several Michigan residents purchased expensive solar-panel systems from a company that promised substantial reductions in their electricity bills. The company’s advertising, prepared in part by entities connected to Trivest Partners, promoted significant savings and government payments, but the plaintiffs experienced little to no reduction in their bills and, in some cases, saw increases. The company, which operated in both Michigan and Florida, later went bankrupt. Alleging fraud and racketeering violations, the plaintiffs brought a civil RICO action and a Michigan Consumer Protection Act claim against Trivest Partners, its affiliates (all Florida entities), and the company founder.In the United States District Court for the Eastern District of Michigan, the two Florida-based Trivest defendants moved to dismiss for lack of personal jurisdiction, arguing that the civil RICO statute did not allow them to be sued in Michigan, as a court in Florida could exercise jurisdiction over all defendants. The district court denied the motion, holding that several practical factors—including the pending status of the case in Michigan, local counsel, and comparative convenience—favored retaining jurisdiction. The plaintiffs later added additional Trivest-related defendants, also Florida citizens, with the court again finding personal jurisdiction.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s interpretation of 18 U.S.C. § 1965(b) de novo. The appellate court held that the district court’s reasons, grounded in convenience and practical considerations, were insufficient as a matter of law to satisfy the “ends of justice require” standard under § 1965(b). The Sixth Circuit concluded that interests of convenience alone cannot justify asserting personal jurisdiction over defendants with no minimum contacts to the forum. The court reversed the district court’s order denying dismissal and vacated the order denying the Trivest defendants’ motions to compel arbitration. View "Hall v. Trivest Partners L.P." on Justia Law

American Airlines contracted with a uniform manufacturer to provide new apparel for its employees. After distribution, many employees reported health issues, including skin and respiratory symptoms, allegedly connected to wearing or being near the uniforms. The airline allowed employees to stop wearing the uniforms, ultimately replacing them. Laboratory and government testing found low levels of chemicals in the uniforms but concluded these were unlikely to cause the reported symptoms. Multiple alternative causes were identified, and the scientific evidence did not support the employees' claims.A group of employees sued American Airlines, the manufacturer, and others in the United States District Court for the Northern District of Illinois, initially seeking class certification under the Class Action Fairness Act (CAFA). After several amended complaints and significant discovery disputes, the plaintiffs dropped their request for class certification, briefly raising questions about the court’s subject matter jurisdiction under CAFA. They later re-pled their class allegations in a fourth amended complaint, and the district court determined it retained jurisdiction. The defendants moved for summary judgment and to exclude the plaintiffs’ expert witnesses, arguing these experts were essential to prove defect and causation.The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that the district court properly retained jurisdiction under CAFA after plaintiffs reasserted class claims. The Seventh Circuit affirmed the exclusion of the plaintiffs’ experts due to unreliable methodologies. It further held that, without expert evidence, the plaintiffs could not establish a defect or causation under strict or negligent products liability. The court also held that neither the Tweedy doctrine nor res ipsa loquitur provided an evidentiary shortcut under the case facts, since the alleged injuries did not inherently indicate a product defect or negligence. The judgment for the defendants was affirmed. View "Zurbriggen v Twin Hill Acquisition, Inc." on Justia Law

Hourly workers at a brewing company’s Williamsburg, Virginia facility alleged that the company failed to pay them for various pre- and post-shift activities, including donning and doffing personal protective equipment, complying with COVID-19 protocols, attending shift-handoff meetings, and handling tools. The company used an electronic badge system for entry but compensated employees based on scheduled shift hours, not actual time on site. Different employees performed these tasks at different times and locations, with some tasks done at home, some during shift hours, and some on the premises outside shift hours. The company committed to pay for all hours actually worked, provided employees notified management about extra time worked.The plaintiffs filed suit under the Virginia Wage Payment Act, the Virginia Overtime Wage Act, and the Fair Labor Standards Act, seeking class certification for wage and hour claims. The United States District Court for the Eastern District of Virginia certified the class, finding that common questions predominated, such as whether the company’s policy resulted in uncompensated mandatory work. The district court’s class definition included all hourly employees at the facility within the relevant timeframe, and it denied the company’s motion to decertify the FLSA collective action.The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that the district court erred by certifying the class without adequately considering significant variations among employees regarding their pre- and post-shift activities, the timing and location of those activities, and the applicable legal standards over time. The appellate court found that the class definition was overly broad and failed to account for differences among employees. Consequently, the Fourth Circuit vacated the class certification order and remanded for further proceedings, allowing the district court to consider narrower subclasses or to deny certification entirely. The appeal regarding the FLSA collective action was dismissed for lack of jurisdiction. View "Overby v. Anheuser-Busch, LLC" on Justia Law

A law firm filed a class action complaint in San Francisco Superior Court on behalf of an employee and similarly situated individuals, alleging wage and hour violations against several beverage distribution companies. This followed the same firm’s earlier, nearly identical class action complaint in Los Angeles County Superior Court, with overlapping claims and parties. The San Francisco action was amended to add claims under the Private Attorneys General Act. After the defense raised concerns about duplicative litigation, the defendants moved to stay the San Francisco case, arguing that the later-filed action was duplicative and should be stayed under the doctrine of exclusive concurrent jurisdiction.The San Francisco Superior Court found substantial overlap between the two cases and granted the stay. In its tentative ruling, the court identified significant misconduct by the plaintiff’s attorneys, including fabricated legal citations and misrepresentations in their opposition to the motion to stay. The court issued an order to show cause regarding sanctions under Code of Civil Procedure section 128.7 and the attorneys’ ethical duties. The firm’s attorneys and a contract attorney responded, denying intentional misconduct and attributing errors to reliance on the contract attorney’s work and alleged citation-checking issues with legal research software. However, the court found their explanations lacking credibility, emphasized their responsibility as counsel of record, and imposed monetary sanctions jointly and severally against the firm and three attorneys, payable to both the defendants and the court.The California Court of Appeal, First Appellate District, Division Two, reviewed the attorneys’ appeal of the sanctions order. The court held that the attorneys had forfeited their procedural challenges by not raising them in the trial court and found no abuse of discretion in imposing sanctions for filing a pleading with fabricated authority and failing to meet ethical and professional obligations. The appellate court affirmed the sanctions order. View "Quinteros v. Harbor Distributing" on Justia Law