Justia Class Action Opinion Summaries

Two students receiving special education services filed a class action lawsuit against the Kanawha County Board of Education, alleging that the Board denied them and other similarly situated students a free appropriate public education (FAPE) as guaranteed by the Individuals with Disabilities Education Act (IDEA). The lawsuit also claimed violations of Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act. The district court certified a class of all Kanawha County Schools students with disabilities who need behavior supports and have experienced disciplinary removals from any classroom.The United States District Court for the Southern District of West Virginia granted the plaintiffs' motion to certify the class, reasoning that the plaintiffs had presented expert evidence of disproportionate rates of suspension for students with disabilities and a detailed qualitative analysis of student records. The court found that these factors revealed a cohesive pattern indicating the absence of an effective system for developing and implementing behavioral supports for students with disabilities. The Board appealed, arguing that the certification of the plaintiff class was inconsistent with Federal Rules of Civil Procedure 23(a) and (b)(2).The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court’s certification order. The Fourth Circuit held that the certified class failed to satisfy Rule 23(a)(2)’s commonality prerequisite. The court found that the plaintiffs did not identify a common contention central to the validity of all class members’ claims. The court noted that the claims were highly diverse and individualized, involving different practices at different stages of the special education process. The absence of a common contention foreclosed class treatment. The case was remanded for further proceedings consistent with the opinion. View "G.T. v. The Board of Education of the County of Kanawha" on Justia Law

In two separate class actions, Kenneth Hasson and Jordan Schnur alleged that FullStory, Inc. and Papa John’s International, Inc. unlawfully wiretapped their online communications using FullStory’s Session Replay Code. This code intercepts detailed user interactions on websites without user consent. Hasson, a Pennsylvania resident, claimed FullStory wiretapped him while he browsed Mattress Firm’s website. Schnur, also from Pennsylvania, alleged similar wiretapping by Papa John’s website.The United States District Court for the Western District of Pennsylvania dismissed both cases for lack of personal jurisdiction. In Hasson’s case, the court found that FullStory, a Delaware corporation with its principal place of business in Georgia, did not have sufficient contacts with Pennsylvania. The court denied Hasson’s request for jurisdictional discovery. In Schnur’s case, the court ruled that Papa John’s, also a Delaware corporation with its principal place of business in Georgia, did not expressly aim its conduct at Pennsylvania, despite operating numerous restaurants in the state.The United States Court of Appeals for the Third Circuit reviewed these dismissals. The court affirmed the dismissal in Schnur’s case, agreeing that Schnur failed to show that Papa John’s expressly aimed its conduct at Pennsylvania under the Calder “effects” test. The court noted that merely operating a website accessible in Pennsylvania does not establish personal jurisdiction.However, the court vacated the dismissal in Hasson’s case and remanded it for further consideration. The court held that the District Court should have also considered whether personal jurisdiction was proper under the traditional test as articulated in Ford Motor Co. v. Montana Eighth Judicial District Court. This test examines whether the defendant purposefully availed itself of the forum and whether the plaintiff’s claims arise out of or relate to the defendant’s contacts with the forum. The court instructed the District Court to reassess FullStory’s contacts with Pennsylvania under this framework. View "Hasson v. Fullstory Inc" on Justia Law

Brian Houston, representing a putative class, filed a lawsuit against Maricopa County and Sheriff Paul Penzone, alleging that the County's practice of posting arrestees' photographs and identifying information on its Mugshot Lookup website violated his substantive and procedural due process rights and his right to a speedy public trial. Houston's mugshot and personal details were posted online for three days following his arrest, even though he was never prosecuted. He claimed this caused him public humiliation, reputational harm, and emotional distress.The United States District Court for the District of Arizona dismissed Houston's claims. The court found that the Mugshot Lookup post was not a condition of pretrial detention and that Houston failed to show a cognizable liberty or property interest under state law for his procedural due process claim. The court also dismissed his Sixth Amendment claim, noting that Houston was not prosecuted and thus had no trial.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court's dismissal of Houston's substantive due process claim, holding that Houston sufficiently alleged that the Mugshot Lookup post caused him actionable harm and that the County's transparency justification did not rationally relate to the punitive nature of the post. The court affirmed the dismissal of Houston's procedural due process claim, as he did not demonstrate a protected liberty or property interest under state law. The court also affirmed the dismissal of his Sixth Amendment claim, as Houston was not prosecuted and thus had no right to a speedy trial.The Ninth Circuit concluded that Houston adequately pleaded a substantive due process claim but failed to state claims for procedural due process and Sixth Amendment violations. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "HOUSTON V. MARICOPA COUNTY" on Justia Law

In the wake of George Floyd's death in May 2020, Los Angeles experienced widespread protests. The plaintiffs, including Black Lives Matter Los Angeles and several individuals, filed a class action lawsuit against the City of Los Angeles and then-LAPD Chief Michel Moore. They alleged that the LAPD used excessive force, arrested protestors without probable cause, and restricted their First Amendment rights. The lawsuit sought to certify four classes: a Direct Force Class, an Arrest Class, an Infraction Class, and an Injunctive Relief Class.The United States District Court for the Central District of California certified all four classes. The court found that the plaintiffs had raised common questions about whether LAPD customs or policies caused their injuries. However, the district court did not rigorously analyze whether the damages classes satisfied the commonality requirement under Rule 23(a) or whether common questions predominated over individual ones under Rule 23(b)(3). The court also failed to address whether the Injunctive Relief Class met the commonality requirement under Rule 23(a).The United States Court of Appeals for the Ninth Circuit vacated the district court’s class certification order. The Ninth Circuit held that the district court did not rigorously analyze whether the plaintiffs produced sufficient evidence to meet the class certification requirements. Specifically, the district court did not adequately address the commonality and predominance requirements for the damages classes or identify common questions for the Injunctive Relief Class. The Ninth Circuit remanded the case with instructions for the district court to fully address Rule 23’s class certification requirements. View "BLACK LIVES MATTER LOS ANGELES V. CITY OF LOS ANGELES" on Justia Law

John Doe, a patient at Ridgeview Institute – Monroe, sued the facility's owners, operators, and CEO after a former employee, Rhonda Rithmire, disclosed patient information without authorization. Doe sought to represent a class of affected patients, alleging multiple claims including breach of contract and negligence. The trial court denied Doe's motion for class certification, finding that he failed to meet the commonality and typicality requirements under OCGA § 9-11-23 (a). Specifically, the court noted that Doe's disclosed information did not include diagnosis or treatment details, unlike other patients whose more sensitive information was revealed.Doe appealed to the Court of Appeals of Georgia, which reversed the trial court's decision. The appellate court found that Doe's claims and those of the putative class arose from the same events and were based on the same legal theories, thus satisfying the typicality requirement. One judge dissented, disagreeing with the majority's interpretation of the typicality and commonality requirements.The Supreme Court of Georgia reviewed the case to determine if the trial court abused its discretion in denying class certification. The Supreme Court concluded that the trial court acted within its discretion in finding a lack of typicality. The court noted that the differences in the type of information disclosed among class members could lead to different legal theories and defenses, making Doe's claims not typical of the class. As a result, the Supreme Court reversed the Court of Appeals' decision, upholding the trial court's denial of class certification. The court did not address the commonality issue, as the lack of typicality alone was sufficient to deny class certification. View "VEST MONROE, LLC v. DOE" on Justia Law

Pilar Domer placed an online order for a can of paint from Menards, selecting an in-store pickup option that incurred a $1.40 fee. Domer later filed a class action lawsuit against Menards, alleging that the company failed to disclose the pickup fee and used it to manipulate prices. Menards moved to compel arbitration based on an arbitration clause in their online terms of order. The district court granted Menards' motion, finding that Domer had agreed to the arbitration terms and that her claims fell within the scope of the arbitration agreement.The United States District Court for the Western District of Wisconsin ruled in favor of Menards, determining that the arbitration agreement was enforceable. The court found that Menards provided adequate notice of the terms and that Domer had unambiguously agreed to them by completing her purchase. The court also concluded that Domer’s claims were related to her purchase contract with Menards and thus fell within the scope of the arbitration agreement.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that Menards' website provided reasonably conspicuous notice of the terms, and Domer unambiguously manifested her assent by submitting her order. The court also found that Domer’s claims, which included violations of consumer protection laws and unjust enrichment, arose from or related to her purchase contract with Menards. Therefore, the claims were within the scope of the arbitration agreement. The Seventh Circuit concluded that the arbitration agreement was valid and enforceable, and Domer’s claims must be arbitrated. View "Domer v. Menard, Inc." on Justia Law

A group of Union Pacific Railroad Company employees filed a class action lawsuit against the company, alleging that its fitness-for-duty program violated the Americans with Disabilities Act (ADA). Todd DeGeer, believing he was part of this class, filed an Equal Employment Opportunity Commission (EEOC) charge and an individual lawsuit after the class was decertified. DeGeer argued that his claims were tolled under the American Pipe & Construction Co. v. Utah doctrine. The district court dismissed his claims as untimely, finding that DeGeer was not a member of the narrowly defined class.The United States District Court for the District of Nebraska initially certified a class that included Union Pacific employees subjected to fitness-for-duty evaluations due to a reportable health event. DeGeer was on a list of employees provided by Union Pacific and submitted a declaration supporting the plaintiffs' certification motion. However, the class definition was later narrowed, and the district court certified the class under this new definition. The Eighth Circuit Court of Appeals later reversed the class certification, leading DeGeer to file his individual claims.The United States Court of Appeals for the Eighth Circuit reviewed the case and reversed the district court's decision. The Eighth Circuit held that DeGeer was entitled to American Pipe tolling because the revised class definition did not unambiguously exclude him. The court emphasized that ambiguities in class definitions should be resolved in favor of applying tolling. Consequently, DeGeer's claims were tolled during the pendency of the class action, making his individual lawsuit timely. The case was remanded for further proceedings. View "DeGeer v. Union Pacific Railroad Co." on Justia Law

TD Ameritrade offers brokerage services to retail investors, allowing them to trade stocks through its online platform. The company routes customer orders to trading venues for execution. Roderick Ford, representing a group of investors, alleged that TD Ameritrade's order-routing practices violated the company's duty of best execution by prioritizing venues that paid the company the most money rather than those providing the best outcomes for customers. Ford claimed this violated § 10(b) of the Securities Exchange Act of 1934 and SEC Rule 10b-5, and that CEO Frederic J. Tomczyk was jointly liable under § 20(a) of the Act.A magistrate judge initially recommended denying Ford's motion for class certification due to the predominance of individual questions of economic loss. However, the district court certified a class, believing Ford's expert's algorithm could address these issues. The Eighth Circuit reversed this decision, stating individual inquiries were still necessary. Ford then proposed a new class definition and moved again for certification under Rule 23(b)(3), (b)(2), and (c)(4). The district court certified the class under Rule 23(b)(3) and alternatively under Rule 23(b)(2) and (c)(4).The United States Court of Appeals for the Eighth Circuit reviewed the district court's certification order for abuse of discretion. The court found that Ford's new theory of economic loss, based on commissions paid, did not align with the previous definition of economic loss and still required individualized inquiries. Consequently, the court held that the district court abused its discretion in certifying the class under Rule 23(b)(3). The court also found that the alternative certifications under Rule 23(b)(2) and (c)(4) were improper due to the predominance of individual issues and the lack of cohesiveness among class members. The Eighth Circuit reversed the district court's order and remanded for further proceedings. View "Ford v. TD Ameritrade Holding Corp." on Justia Law

Four former Tesla employees, Sharonda Taylor, Shaka Green, Tatianna Smith, and Zenobia Milligan, requested personnel records from Tesla under the California Labor Code. These individuals are also part of a class action lawsuit, Vaughn v. Tesla, which alleges racial discrimination and harassment at Tesla's Fremont plant. Despite the requests, Tesla did not provide the requested records, citing a stay in the Vaughn case due to an ongoing appeal. The plaintiffs then filed a Private Attorneys General Act (PAGA) action against Tesla for failing to comply with the Labor Code.The Superior Court of California, County of Alameda, denied Tesla's anti-SLAPP motion, which argued that the PAGA claims arose from protected petitioning activity related to the Vaughn case. The court found that the plaintiffs' requests for personnel records were independent of the Vaughn litigation and were merely an exercise of their statutory rights under the Labor Code.The California Court of Appeal, First Appellate District, Division Four, affirmed the lower court's decision. The appellate court held that Tesla's refusal to provide the requested records did not constitute protected activity under the anti-SLAPP statute. The court distinguished this case from Crossroads Investors, L.P. v. Federal National Mortgage Assn., noting that the plaintiffs' PAGA claims did not rely on any "written or oral statement or writing" by Tesla. The court also found that Tesla's conduct did not meet the criteria for protection under the anti-SLAPP statute's "catchall" provision, as it did not contribute to any public issue or debate. Consequently, the court affirmed the denial of Tesla's anti-SLAPP motion. View "Taylor v. Tesla, Inc." on Justia Law

Plaintiffs from twenty-six states sought class certification in their lawsuit against General Motors, LLC (GM) for alleged defects in the 8L45 and 8L90 transmissions of vehicles purchased between 2015 and 2019. Plaintiffs experienced "shudder" and shift quality issues that persisted despite repairs. GM argued that the class lacked standing and that individualized issues would predominate over common issues in the class-action suit.The United States District Court for the Eastern District of Michigan determined that the Plaintiffs had standing and could satisfy Federal Rule of Civil Procedure 23, thus certifying the class. GM appealed, claiming the district court abused its discretion in certifying the class.The United States Court of Appeals for the Sixth Circuit reviewed the case and held that the Plaintiffs had standing, as they alleged overpayment for defective products, which suffices for Article III standing. The court also found that the district court did not abuse its discretion in certifying the class, as the common questions of law and fact predominated over individualized issues. The court addressed GM's arguments regarding state laws requiring manifest defects, reliance, causation, and merchantability, concluding that these issues did not preclude class certification. The court also held that GM had waived its right to arbitration by engaging in litigation and seeking dispositive rulings on the merits.The Sixth Circuit affirmed the district court's class certification, allowing the class-action lawsuit against GM to proceed. View "Speerly v. General Motors, LLC" on Justia Law