Justia Class Action Opinion Summaries

The Eighth Circuit reversed the district court's order certifying a nationwide class of plaintiffs in a case involving allegedly deceptive advertising practices. The action arose out of allegedly deceptive advertising associated with RIDGID brand vacuums. The district concluded that all class members' claims would be governed by Missouri law and thus determined class resolution was appropriate.The court held that the claims of non-Missouri residents did not relate to “trade or commerce . . . in or from the state of Missouri” and the Missouri Merchandising Practices Act could not be applied to them. The court also held that the district court should have conducted separate choice of law analyses for the breach of warranty and unjust enrichment claims. Accordingly, the court remanded for further proceedings. View "Hale v. Emerson Electric Co." on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the order of the circuit court denying motions to compel arbitration of a class-action complaint filed by Appellees, holding that Appellants failed to meet their burden of proving a valid and enforceable arbitration agreement with respect to certain agreements but that Appellants met their burden to prove the validity of the remainder of the arbitration agreements.Appellees filed a class-action complaint against Appellants, a nursing home and related entities, alleging that Appellants had breached their admission and provider agreements, violated the Arkansas Deceptive Trade Practices Act, committed negligence and civil conspiracy, and had been unjustly enriched. Appellants' filed four motions to compel arbitration with respect to ten class members/residents. The circuit court denied the motions. The Supreme Court affirmed in part and reversed in part, holding (1) certain arbitration agreements contained deficiencies that prevented Appellants from meeting their burden of proving a valid and enforceable arbitration agreement; and (2) Appellants met their burden to prove the validity of the remainder of the arbitration agreements not already discussed. View "Robinson Nursing & Rehabilitation Center, LLC v. Phillips" on Justia Law

The Supreme Court affirmed the order of the circuit court dismissing Appellant's illegal-exaction complaint against the City of Blytheville, Arkansas, holding that the circuit court did not abuse its discretion in dismissing the complaint.The City passed an ordinance calling for a special election to be held on a one-cent sales and use tax to be collected for fifteen months. The proposed tax was approved at the special election. Appellant later filed a class action complaint alleging that the excess revenue was an illegal exaction because the tax was approved in order to pay the City's debt to the federal government. The trial court dismissed the complaint, finding that, based on the wording of the ballot title, the City's use of the excess funds to pay payroll taxes was authorized and there was no illegal exaction. The Supreme Court affirmed, holding that the trial court properly utilized the enabling ordinance and ballot title in determining the approved uses for the excess funds. View "Carlock v. City of Blytheville" on Justia Law

In this class action, the Supreme Court affirmed the class certification order and the supplemental order of the circuit court, holding that the certified class satisfied the requirements of commonality, predominance, typicality, superiority, and ascertainability.The circuit court's order certified the class as individuals who attended C-1 Truck Driving School in North Little Rock through Driver Solutions' "company-paid training" during a certain time period and did not complete one year of employment with the carrier. The circuit court then entered a supplemental order explaining the phrase "company-paid training." The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in determining that each requirement for class certification was satisfied in this case. View "Driver Solutions, LLC v. Downey" on Justia Law

The Court of Appeals affirmed the order of the Appellate Division modifying Supreme Court's dismissal of Plaintiffs' amended class action complaint by denying the part of the motion seeking dismissal of the class action claims against Defendants except to the extent those allegations addressed the cause of action for violation of N.Y. Gen. Bus. Law 349, holding that the claims for class relief should not have been dismissed without a judicial determination as to whether the prerequisites of N.Y. C.P.L.R. 902 had been satisfied.Plaintiffs, current and former tenants in buildings within multiple apartment buildings, alleged that individual corporate defendants that owned various buildings at issue were owned or controlled by a single holding company and that Defendants, in an effort to extract additional value from the properties, engaged in improper and illegal conduct" by, among other things, inflating rents above the amounts Defendant were legally permitted to charge. Before an answer was filed, Supreme Court dismissed the complaint, concluding that there was no basis for class relief. The Appellate Division modified Supreme Court's order, concluding that dismissal at this stage was premature. The Court of Appeals affirmed, holding that dismissal of class claims based on allegations of a methodical attempt to illegally inflate rents was premature. View "Maddicks v Big City Properties, LLC" on Justia Law

The Supreme Court granted a writ of prohibition sought by Municipal Water Works to challenge an order issued by the circuit court granting Plaintiffs' motion for class certification, holding that the circuit court failed to conduct a thorough analysis of the class prerequisites in W. VA. R. Civ. P. 23(a), and therefore, the order granting class certification must be vacated.Plaintiffs, individually and on behalf of a class of individuals that were customers of Municipal Water, filed a complaint in the circuit court alleging that each putative class member was exposed to illness-causing pollutants in their water supply. After a hearing, the circuit court entered an order granting class certification. The Supreme Court vacated the order, holding that the circuit court's order did not contain a thorough analysis of the Rule 23(a) factors. View "State ex rel. Municipal Water Works v. Honorable Derek C. Swope" on Justia Law

Plaintiff, on behalf of himself and a proposed class of similarly situated county utility ratepayers, filed suit against the city and the Department of Water and Power (DWP), alleging that DWP overcharged ratepayers for electric utility usage. After a class was certified for a proposed settlement, an unnamed class member timely objected and filed an application to intervene. The trial court denied the application, overruled the unnamed class member's objection, approved the settlement, and entered a judgment under the settlement terms.The Court of Appeal dismissed the unnamed class member's appeal, holding that she was not a party of record and has not utilized the procedures available to alter her status. Therefore, she lacked standing to appeal from the judgment. View "Eck v. City of Los Angeles" on Justia Law

The Supreme Court reversed the judgment of the circuit court holding the City of Kansas City in civil contempt of a 1976 modified judgment, holding that the parties could not bring a contempt action to enforce the 1976 modified judgment because they were not parties to the litigation and the 1976 plaintiffs were not certified as a class.Sophian Plaza Association and a class of similarly situated plaintiffs brought claims of breach of injunction, breach of contract, specific performance, and civil contempt stemming from the City's termination of a trash rebate program. The court certified a class and then entered judgment in favor of the class on its claims. The court of appeals affirmed. The Supreme Court reversed, holding that the class could not avail itself of enforcement proceedings brought upon the 1976 modified judgment because they were not parties to the litigation nor were the 1976 plaintiffs certified as a class under Mo. R. Civ. p. 52.08. View "Sophian Plaza Ass'n v. City of Kansas City, Missouri" on Justia Law

Plaintiffs sued, claiming that certain Tristar pressure cookers had defective lids that could come open while the cookers were in use, exposing the user to possible injury. The district court certified three separate state classes for trial: Ohio, Pennsylvania, and Colorado. During a trial recess, the parties agreed to a settlement with a nationwide class. The parties agreed to the principal amount but, with Tristar’s agreement not to dispute an award at or below $2.5 million, deferred determination of attorneys’ fees. Class members would receive a coupon to purchase a different Tristar product and a warranty extension. The court calculated the value of the coupons and warranty extensions as $1,020,985 and approved attorneys’ fees of $1,980,382.59. At a fairness hearing, Arizona made its first appearance, arguing as amicus, along with the U.S. Department of Justice, that the settlement was unfair because of the division between the principal settlement and attorneys’ fees. None of the class joined in objections to the settlement. The court indicated that it would approve the settlement. Before the court issued its order, Arizona sought to officially intervene under either Rule 24(a) Rule 24(b). The court rejected each of Arizona’s requests for lack of Article III standing. The Sixth Circuit dismissed an appeal, rejecting the state’s arguments that it had standing under the parens patriae doctrine, under the Class Action Fairness Act, 28 U.S.C. 1715, and because it has a participatory interest as a “repeat player.” View "Kenneth Chapman v. Tristar Products, Inc." on Justia Law

Dancel sued Groupon, an online seller of discount vouchers, alleging Groupon had used her photograph to promote a restaurant voucher. Groupon had collected the photograph from Dancel’s public Instagram account based on data linking it to the restaurant’s location. She sought damages under the Illinois Right of Publicity Act on behalf of a class of Illinois residents whose Instagram photographs have appeared on a Groupon offer. The parties litigated in state court until Dancel moved to certify a class of “[a]ll persons who maintained an Instagram Account and whose photograph ... was ... acquired and used on a groupon.com webpage for an Illinois business.” The class was not defined by its members’ residency. In response, Groupon filed a notice of removal. The Class Action Fairness Act, 28 U.S.C. 1453, permits removal of a proposed class action to federal court if there is minimal diversity, meaning any member of the plaintiff class is a citizen of a state different from any defendant. Groupon, a citizen of Illinois and Delaware, did not identify any class member or his citizenship. Dancel argued that Groupon had waived its right to remove. The district court rejected Dancel’s waiver argument and denied remand but did not address minimal diversity or direct Groupon to cure its allegations. The parties then litigated class certification, which the court denied on predominance grounds. On appeal, Dancel revisited the removal issue. The Seventh Circuit ordered a limited remand for the district court to address limited diversity and secure its jurisdiction. View "Dancel v. Groupon, Inc." on Justia Law