Justia Class Action Opinion Summaries

Nabors Corporate Services, Inc. (Nabors) performed oil well plug and abandonment work for the City of Long Beach (the City) between 2012 and 2014. The City had contracted with Tidelands Oil Production Company (Tidelands) for services on the Gerald Desmond Bridge Replacement Project, and Tidelands subcontracted the work to Nabors. The City and Tidelands had concluded that the work was not subject to prevailing wage laws, and Nabors was not informed otherwise during the bid process. After completing the work, Nabors faced a class action from its employees for unpaid prevailing wages, which led to arbitration awards and federal court judgments against Nabors.The Superior Court of Los Angeles County sustained demurrers by the City and Tidelands, dismissing Nabors’s claims for indemnity under Labor Code sections 1781 and 1784. The court ruled that section 1784 could not be applied retroactively to Tidelands and that the arbitration awards confirmed by the federal court did not qualify as court decisions under section 1781.The California Court of Appeal, Second Appellate District, Division Five, reviewed the case. The court affirmed the dismissal of the section 1784 claim against Tidelands, agreeing that the statute could not be applied retroactively. However, the court reversed the dismissal of the section 1781 claim against the City, holding that the federal court’s confirmation of arbitration awards did qualify as court decisions classifying the work as public work. The case was remanded with instructions to enter a new order overruling the City’s demurrer to the section 1781 cause of action. Nabors was awarded costs on appeal against the City, while Tidelands was awarded costs on appeal against Nabors. View "Nabors Corporate Services, Inc. v. City of Long Beach" on Justia Law

The Coachella Valley Water District (Water District) appealed a judgment finding that the rates it charged for Coachella Canal water violated Article XIII C of the California Constitution. The Water District argued that the rates were lawful and that no refund remedy was authorized. The court rejected both arguments, finding the rates unlawful and that a refund remedy was constitutionally mandated.In the lower court, the Superior Court of Riverside County ruled that the Water District's Canal Water rates and the Irrigation Water Availability Assessment (IWAA) violated Proposition 218. The court found that the Water District's historical priority argument was not persuasive and that the Water District had made no attempt to show that the rates complied with the California Constitution. The court deferred ruling on remedies and later awarded Class 2 customers approximately $17.5 million in refunds and interest for invalid charges from March 2018 through June 2022.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court held that Howard Jarvis Taxpayers Association (Howard Jarvis) had standing to challenge the Class 2 rates because domestic customers paid the rates indirectly. The court found that the Class 2 rates were taxes under Article XIII C and did not fall under any exceptions. The court rejected the Water District's arguments that the rates were justified based on historical priority and that they were expenditures of funds. The court also found that the IWAA was an assessment under Proposition 218 and that the Water District failed to show it was proportional to the benefits conferred on the properties.The court affirmed the lower court's ruling on liability and the amount of refund relief awarded. However, the court found that the injunction in the judgment was overbroad and modified the judgment to strike the paragraph enjoining the Water District from imposing any future Canal Water rates and charges that did not comply with Proposition 218. As modified, the judgment was affirmed, and Howard Jarvis was awarded its costs on appeal. View "Howard Jarvis Taxpayers Assn. v. Coachella Valley Water Dist." on Justia Law

Armando Guevara worked as a domestic service employee for Robert and Maria Zamora for over a decade, performing various tasks such as cleaning, car maintenance, and grocery shopping. Occasionally, he also provided services for the Zamoras' businesses, Lafise Corporation and Latin American Financial Services, Inc. (LAFS). Guevara was paid $1,365.88 biweekly, but there was no written employment agreement, and the parties disagreed on whether this amount represented a salary or an hourly wage. The Zamoras claimed they paid him an hourly rate with overtime, while Guevara asserted he was paid a salary without proper overtime compensation.Guevara filed a putative class action against the Zamoras, Lafise, and LAFS for unpaid overtime wages under the Fair Labor Standards Act (FLSA). The United States District Court for the Southern District of Florida granted summary judgment in favor of the defendants, finding that Guevara was not covered by the FLSA through either "enterprise coverage" or "individual coverage." The court also found that Guevara was fully compensated for all his overtime work hours based on the Zamoras' testimony and calculations.The United States Court of Appeals for the Eleventh Circuit reviewed the case and found that the district court erred in granting summary judgment. The appellate court determined that there was a genuine dispute regarding Guevara's regular hourly rate and, therefore, his overtime rate. The court noted that the Zamoras did not maintain accurate records, and the evidence presented created a genuine issue of fact that should be determined by a jury. The appellate court also vacated the district court's ruling on whether Lafise was a joint employer, as the lower court failed to provide sufficient reasoning and did not address the relevant factors. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Guevara v. Lafise Corp." on Justia Law

The plaintiffs, who are military members, filed a class action against Citibank, alleging violations of the Servicemembers Civil Relief Act (SCRA) and other statutes. They claimed Citibank improperly charged them higher interest rates and fees on their credit card balances after they left active duty, contrary to the SCRA's protections. The credit card agreements included arbitration clauses that required disputes to be resolved individually, not as class actions.The United States District Court for the Eastern District of North Carolina denied Citibank's motion to compel arbitration, holding that the SCRA allowed servicemembers to bring class actions in federal court despite any prior agreement to arbitrate. The court interpreted the SCRA's provision allowing class actions "notwithstanding any previous agreement to the contrary" as overriding the Federal Arbitration Act (FAA).The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court's decision. The Fourth Circuit held that the SCRA does not explicitly prohibit arbitration agreements and that the FAA requires enforcement of such agreements unless there is a clear congressional command to the contrary. The court found that the SCRA's language did not provide such a command and that the arbitration agreements should be enforced according to their terms, which included individual arbitration.The Fourth Circuit remanded the case with instructions to compel arbitration for all claims except those under the Military Lending Act (MLA). The court noted that the MLA explicitly prohibits arbitration agreements for disputes involving the extension of consumer credit to servicemembers. The district court was instructed to determine whether the MLA applied to the plaintiffs' credit card accounts and to address any related issues. View "Espin v. Citibank, N.A." on Justia Law

John Doe filed a putative class action against SSM Health Care Corporation in Missouri state court, alleging that SSM shared private health information with third-party marketing services without authorization, violating Missouri law. Doe claimed that SSM's MyChart patient portal transmitted personal health data to third-party websites like Facebook. The lawsuit included nine state law claims, such as violations of the Missouri Wiretap Statute and the Computer Tampering Act.SSM removed the case to federal court, citing the federal officer removal statute and the Class Action Fairness Act (CAFA). Doe moved to remand the case to state court. The United States District Court for the Eastern District of Missouri rejected SSM's arguments, ruling that SSM was not "acting under" a federal officer and that Doe's proposed class was limited to Missouri citizens, thus lacking the minimal diversity required under CAFA. The district court remanded the case to state court.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that SSM did not meet the criteria for federal officer removal because it was not acting under the direction of a federal officer. The court also held that the proposed class was limited to Missouri citizens, which destroyed the minimal diversity necessary for CAFA jurisdiction. Consequently, the Eighth Circuit affirmed the district court's remand order. View "Doe v. SSM Health Care Corporation" on Justia Law

Rebecca Petta filed a class-action complaint in the circuit court of Champaign County against Christie Business Holdings Company, P.C., doing business as Christie Clinic. Petta alleged that Christie negligently failed to prevent unauthorized access to its business email account, which potentially exposed patients' private personal data, including Social Security numbers and health insurance information. Christie moved to dismiss the complaint, and the trial court granted the motion.The trial court found that Petta had standing due to an inference of injury from unauthorized use of her phone number and city in a loan application. However, the court dismissed the complaint for failing to state a valid claim under existing law and due to the economic loss doctrine. The appellate court affirmed the dismissal but on the grounds that Petta lacked standing, as the alleged increased risk of identity theft was too speculative and the unauthorized loan application did not involve her private personal data.The Supreme Court of Illinois reviewed the case and agreed with the appellate court. The court held that Petta's allegations of increased risk of harm were insufficient to confer standing in a complaint seeking monetary damages. The court also found that the unauthorized loan application, which used only Petta's publicly available phone number and city, was not fairly traceable to Christie's alleged misconduct. Consequently, the court affirmed the appellate court's judgment, concluding that Petta lacked standing to bring her claims. View "Petta v. Christie Business Holding Co., P.C." on Justia Law

Plaintiffs, a class of individuals, filed mortgage foreclosure complaints in Illinois circuit courts and paid "add-on" filing fees mandated by section 15-1504.1 of the Code of Civil Procedure. They challenged the constitutionality of these fees, asserting that the statute violated the free access clause of the Illinois Constitution. The Illinois Supreme Court previously agreed, declaring the statute unconstitutional and affirming an injunction against its enforcement.The Will County circuit court initially certified the class and granted partial summary judgment, finding the statute unconstitutional. The appellate court reversed, and the case was remanded. On remand, plaintiffs pursued a refund of the fees. The circuit court dismissed the refund claim, citing sovereign immunity, which bars claims against the State. The appellate court reversed, holding that the circuit court had jurisdiction under the officer-suit exception to sovereign immunity, which allows suits against state officials for unconstitutional actions.The Illinois Supreme Court reviewed the case and held that while the officer-suit exception allowed the circuit court to enjoin the enforcement of the unconstitutional statute, it did not apply to the refund claim. The court determined that the refund claim was a retrospective monetary award to redress a past wrong, which falls under the jurisdiction of the Court of Claims, not the circuit court. Consequently, the Illinois Supreme Court reversed the appellate court's judgment and affirmed the circuit court's dismissal of the refund claim. View "Walker v. Chasteen" on Justia Law

The plaintiffs, Carmen Mercado and Jorge Lopez, filed a class action complaint against their former employer, S&C Electric Company, in the circuit court of Cook County. They alleged that S&C underpaid their overtime wages by excluding certain performance bonuses from the "regular rate" of pay used to calculate overtime. S&C argued that the bonuses were statutorily excluded from the regular rate of pay and that they had made adjusted payments to cover any alleged unpaid wages.The circuit court granted S&C's motion to dismiss the complaint with prejudice, finding that the adjusted payments satisfied the alleged underpayment. The appellate court affirmed the circuit court's judgment, agreeing that the bonuses were properly excluded from the regular rate of pay and that the adjusted payments fully compensated the plaintiffs.The Supreme Court of Illinois reviewed the case and reversed the lower courts' judgments. The court held that the performance bonuses should have been included in the regular rate of pay for calculating overtime wages. The court found that the bonuses were not gifts but compensation for services performed, and thus did not fall under the exclusion in section 210.410(a) of the regulations. Additionally, the court held that the adjusted payments did not fully compensate the plaintiffs for their statutory damages, including treble damages, monthly interest, and attorney fees, as required by section 12(a) of the Minimum Wage Law.The Supreme Court of Illinois remanded the case to the circuit court for further proceedings consistent with its opinion. View "Mercado v. S&C Electric Co." on Justia Law

Phillip and Sara Alig, along with Daniel and Roxanne Shea, filed a class action lawsuit against Quicken Loans, Inc. (now Rocket Mortgage, LLC) and Title Source, Inc. (now Amrock, Inc.). They alleged that during the refinancing of their home mortgage loans, they paid for appraisals that were not independent because the defendants had provided appraisers with the homeowners' estimates of their homes' value. They claimed this made the appraisals worthless and asserted statutory, breach of contract, and conspiracy claims.The United States District Court for the Northern District of West Virginia certified a class of West Virginia citizens who refinanced mortgage loans with Quicken and received appraisals that included an estimate of the property's value. The court granted summary judgment to the plaintiffs, awarding over $10.6 million in damages. The court found that the plaintiffs had established a conspiracy between the defendants.The United States Court of Appeals for the Fourth Circuit affirmed the class certification and summary judgment on the statutory and conspiracy claims but vacated and remanded the breach of contract claim. The Supreme Court vacated the Fourth Circuit's judgment and remanded the case for reconsideration in light of TransUnion LLC v. Ramirez, which emphasized that every class member must have Article III standing to recover damages.On remand, the district court reinstated its original judgment, stating that TransUnion did not affect the class's standing. However, the Fourth Circuit concluded that the plaintiffs failed to establish that class members suffered concrete harm from the defendants' actions. The court reversed the district court's judgment certifying the class and awarding damages, affirming the judgment on the named plaintiffs' statutory and conspiracy claims, and vacating the judgment on the breach of contract claim, remanding it for further proceedings. View "Alig v. Rocket Mortgage, LLC" on Justia Law

Freedom Vans LLC, a company that converts and customizes vans into mobile houses, hired Jeremy David and Mark Springer. David, a self-taught carpenter, was hired in 2019 and later promoted to foundations manager. Springer, an automotive and maritime mechanic, was hired in 2020 as an electrician. Both employees earned less than twice the minimum wage and signed a noncompete agreement prohibiting them from engaging in any business that competed with Freedom Vans. They claimed they declined additional work offers due to fear of termination and legal action. They stopped working for Freedom Vans in 2021.David and Springer filed a class action lawsuit in 2022, alleging the noncompete agreement violated chapter 49.62 RCW, which regulates noncompete clauses in employment contracts. They sought damages and injunctive and declaratory relief. The superior court granted summary judgment to Freedom Vans, reasoning that RCW 49.62 does not restrict an employer’s right to require employee loyalty and avoidance of conflicts of interest. The court denied Freedom Vans' request for attorney fees. Both parties appealed.The Washington Supreme Court reviewed the case. The court held that noncompete agreements for employees earning less than twice the minimum wage must be reasonable and narrowly construed in light of the legislature’s intent to protect low wage workers and promote workforce mobility. The court reversed the Court of Appeals' decision, concluding that prohibiting employees from providing any kind of assistance to competitors exceeds a narrow construction of the duty of loyalty. The case was remanded to the superior court to determine the reasonableness of the noncompete agreement and assess damages and attorney fees. View "Springer v. Freedom Vans LLC" on Justia Law