Justia Class Action Opinion Summaries

A class of stock purchasers alleged that Anadarko Petroleum Corporation fraudulently misrepresented the potential value of its Shenandoah oil field project in the Gulf of Mexico, violating federal securities law. The plaintiffs claimed that a decline in Anadarko’s stock price resulted from the company's disclosure that the Shenandoah project was dry and that Anadarko was taking a significant write-off for the project. The plaintiffs invoked the Basic presumption, a legal principle that allows courts to presume an investor's reliance on any public material misrepresentations if certain requirements are met.The District Court for the Southern District of Texas certified the class, relying on new evidence presented by the plaintiffs in their reply brief. Anadarko argued that it was not given a fair opportunity to respond to this new evidence and appealed the decision.The United States Court of Appeals for the Fifth Circuit agreed with Anadarko, stating that the district court should have allowed a sur-reply when the plaintiffs presented new evidence in their reply brief. The court held that when a party raises new arguments or evidence for the first time in a reply, the district court must either give the other party an opportunity to respond or decline to rely on the new arguments and evidence. The court also agreed that the district court failed to perform a full Daubert analysis, a standard for admitting expert scientific testimony. The court vacated the class certification order and remanded the case for further proceedings. View "Georgia Firefighters' Pension Fund v. Anadarko Petroleum Corp." on Justia Law

This case involves a dispute between plaintiffs Michelle Beverage and Joseph Mejia, and defendant Apple, Inc. The plaintiffs filed a class action complaint alleging that Apple's restrictive contractual terms and coercive conduct towards software developers on its App Store constituted unlawful and unfair practices that violated the Cartwright Act and the Unfair Competition Law (UCL). The plaintiffs specifically focused on Apple's treatment of one developer, Epic Games, Inc., and its gaming application, Fortnite. The trial court sustained a demurrer brought by Apple without leave to amend, applying the Colgate doctrine and the holding of Chavez v. Whirlpool Corporation. The court determined that the plaintiffs did not and could not state causes of action under either legal regime as a matter of law.The trial court's decision was based on the application of the Colgate doctrine and the holding of Chavez v. Whirlpool Corporation. The court found that the plaintiffs did not and could not state causes of action under either the Cartwright Act or the UCL as a matter of law. The plaintiffs appealed only one aspect of the trial court's ruling, arguing that the court erred by relying on Chavez to sustain the demurrer to their UCL cause of action alleging unfair practices by Apple towards Epic Games.The Court of Appeal of the State of California Sixth Appellate District affirmed the trial court's judgment. The appellate court disagreed with the plaintiffs' argument that Chavez was inconsistent with the California Supreme Court’s decision in Cel-Tech Communications, Inc. v. Los Angeles Cellular Telephone Company. The court found that the trial court correctly relied on Chavez to sustain the demurrer without leave to amend. The court held that the plaintiffs did not state a claim as a matter of law under the "unfair" prong of the UCL, considering the trial court's ruling that Apple's practices constituted permissible unilateral conduct. View "Beverage v. Apple, Inc." on Justia Law

The case involves a consumer class action against Nutramax Laboratories, Inc. and Nutramax Laboratories Veterinary Sciences, Inc. (collectively, “Nutramax”), alleging that Nutramax violated the California Consumers Legal Remedies Act by falsely marketing its pet health product, Cosequin, as promoting healthy joints in dogs. The plaintiffs, Justin Lytle and Christine Musthaler, claimed that Cosequin provided no such health benefits. The district court certified a class of California purchasers of certain Cosequin products who were exposed to the allegedly misleading statements.The district court had certified the class based on the proposed damages model of Plaintiffs’ expert, Dr. Jean-Pierre Dubé, to find that common questions predominated as to injury. Nutramax appealed, arguing that the district court erred in relying on an unexecuted damages model to certify the class and that the element of reliance was not susceptible to common proof.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The appellate court held that there was no general requirement that an expert actually apply to the proposed class an otherwise reliable damages model in order to demonstrate that damages are susceptible to common proof at the class certification stage. The court also rejected Nutramax’s contention that the district court incorrectly concluded that the element of reliance was susceptible to common proof. The district court properly found that classwide reliance may be established under the CLRA through proof that a misrepresentation is material. View "LYTLE V. NUTRAMAX LABORATORIES, INC." on Justia Law

The case involves a class action lawsuit brought against the Illinois Department of Corrections (IDOC) by four parents who were convicted of sex offenses and were on mandatory supervised release (MSR). The plaintiffs challenged an IDOC policy that restricts contact between a parent convicted of a sex offense and their minor child while the parent is on MSR. The plaintiffs argued that this policy violates their Fourteenth Amendment rights to procedural and substantive due process.The district court upheld the policy, with two exceptions. It ruled that the policy's ban on written communications was unconstitutional and that IDOC must allow a parent to submit a written communication addressed to their child for review and decision within seven calendar days. The plaintiffs appealed, challenging the policy's restrictions on phone and in-person contact.The United States Court of Appeals for the Seventh Circuit affirmed in part and reversed in part. The court agreed with the district court that the policy does not violate procedural due process. However, it held that the policy's ban on phone contact violates substantive due process. The court found that call monitoring is a ready alternative to the phone-contact ban that accommodates the plaintiffs’ right to enjoy the companionship of their children at a de minimis cost to IDOC’s penological interests. View "Montoya v. Jeffreys" on Justia Law

The case involves Sherry and David Lewis, who sued their auto insurer, GEICO, for allegedly breaching their insurance contract when their car was totaled. The Lewises claimed that GEICO undercompensated them by applying a "condition adjustment" that artificially reduced its valuation of their car and by failing to reimburse them for taxes and fees necessary to replace the car. They sought to certify a class of similarly underpaid insureds for each instance of underpayment.The District Court certified both classes under Federal Rule of Civil Procedure 23. GEICO appealed the decision, challenging the certification of the classes.The United States Court of Appeals for the Third Circuit affirmed the order certifying the class for the taxes-and-fees claim. However, the court found that the Lewises lacked standing to bring the condition-adjustment claim as they failed to show that GEICO caused them concrete harm when it applied the condition adjustment. Therefore, the court vacated the District Court’s order in part and remanded with instructions to dismiss the condition-adjustment claim.Regarding the taxes-and-fees claim, the court found that the Lewises met the requirements for standing as they alleged financial harm stemming from GEICO's pre-2020 practice of declining to pay taxes and fees to lessee insureds. The court also found that the class was ascertainable, meeting the requirements for class certification. View "Lewis v. GEICO" on Justia Law

The plaintiff, Ryan S., filed a class action lawsuit against UnitedHealth Group, Inc. and its subsidiaries (collectively, “UnitedHealthcare”) under the Employee Retirement Income Security Act of 1974 (“ERISA”). He alleged that UnitedHealthcare applies a more stringent review process to benefits claims for outpatient, out-of-network mental health and substance use disorder (“MH/SUD”) treatment than to otherwise comparable medical/surgical treatment. Ryan S. asserted that by doing so, UnitedHealthcare violated the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 (“Parity Act”), breached its fiduciary duty, and violated the terms of his plan.The district court granted UnitedHealthcare’s motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) based primarily on its conclusions that Ryan S. failed to allege that his claims had been “categorically” denied and insufficiently identified analogous medical/surgical claims that he had personally submitted and UnitedHealthcare had processed more favorably.The United States Court of Appeals for the Ninth Circuit reversed in part and affirmed in part the district court’s judgment. The panel concluded that Ryan S. adequately stated a claim for a violation of the Parity Act. The panel explained that an ERISA plan can violate the Parity Act in different ways, including by applying, as Ryan S. alleged here, a more stringent internal process to MH/SUD claims than to medical/surgical claims. The panel also concluded that Ryan S. alleged a breach of fiduciary duty. However, as Ryan S. failed to identify any specific plan terms that the alleged practices would violate, the panel affirmed the dismissal of his claims based on a violation of the terms of his plan. The case was remanded for further proceedings. View "Ryan S. v. UnitedHealth Group, Inc." on Justia Law

Yasmin Varela filed a class action lawsuit against State Farm Mutual Automobile Insurance Company (State Farm) after a car accident. Varela's insurance policy with State Farm entitled her to the "actual cash value" of her totaled car. However, she alleged that State Farm improperly adjusted the value of her car based on a "typical negotiation" deduction, which was not defined or mentioned in the policy. Varela claimed this deduction was arbitrary, did not reflect market realities, and was not authorized by Minnesota law. She sued State Farm for breach of contract, breach of the covenant of good faith and fair dealing, unjust enrichment, and violation of the Minnesota Consumer Fraud Act (MCFA).State Farm moved to dismiss the complaint, arguing that Varela's claims were subject to mandatory, binding arbitration under the Minnesota No-Fault Automobile Insurance Act (No-Fault Act). The district court granted State Farm's motion in part, agreeing that Varela's claims for breach of contract, breach of the covenant of good faith and fair dealing, and unjust enrichment fell within the No-Fault Act's mandatory arbitration provision. However, the court found that Varela's MCFA claim did not seek the type of relief addressed by the No-Fault Act and was neither time-barred nor improperly pleaded, and thus denied State Farm's motion to dismiss this claim.State Farm appealed, arguing that Varela's MCFA claim was subject to mandatory arbitration and should have been dismissed. However, the United States Court of Appeals for the Eighth Circuit dismissed the appeal for lack of jurisdiction. The court found that State Farm did not invoke the Federal Arbitration Act (FAA) in its motion to dismiss and did not file a motion to compel arbitration. The court concluded that the district court's order turned entirely on a question of state law, and the policy contained no arbitration provision for the district court to "compel." Therefore, State Farm failed to establish the court's jurisdiction over the interlocutory appeal. View "Varela v. State Farm Mutual Automobile Insurance Co." on Justia Law

The case revolves around Lisa Stone, a tenant who signed a lease agreement that required her to provide maintenance services for which she alleges she was not compensated, in violation of Minnesota law. She initiated a class-action lawsuit against Invitation Homes, Inc., the parent company of her landlord, and THR Property Management, L.P., the manager of the leased property. Stone later amended her complaint to include various subsidiaries of Invitation Homes as defendants. Some of these subsidiaries argued that Stone lacked standing to sue them as she had not alleged that they had caused any injuries.The district court denied the subsidiaries' motion to dismiss. The subsidiaries appealed this decision to the court of appeals, which reversed the district court's decision and dismissed Stone's claims against the subsidiaries. The court of appeals reasoned that Stone lacked standing to bring her claims under the theory for standing found by the district court, and the juridical-link doctrine was improperly raised by Stone for the first time on appeal and did not apply in this case.Stone appealed to the Supreme Court of Minnesota, arguing that she has standing against the subsidiaries under the juridical-link doctrine. This doctrine posits that in a class action in which a named plaintiff has not alleged an injury caused by all defendants, a class may be certified when all defendants are linked by a conspiracy or concerted scheme that harmed the class. However, the Supreme Court affirmed the decision of the court of appeals, stating that Stone had forfeited the ability to have the merits of standing under the juridical-link doctrine determined on appeal as she failed to assert standing based on the juridical-link doctrine in the district court. View "Stone, vs. Invitation Homes, Inc." on Justia Law

The case involves an appeal by SaniSure, Inc., against a trial court's decision not to compel arbitration in a dispute with its former employee, Jasmin Vazquez. Vazquez initially worked for SaniSure from July 2019, and as part of her employment, she signed an agreement to resort to arbitration for any disputes that might arise from her employment. She eventually terminated this employment in May 2021. She returned to work for SaniSure four months later without signing any new arbitration agreement or discussing the application of the previous arbitration agreement to her new employment.Vazquez's second employment with SaniSure ended in July 2022. Later, she filed a class-action complaint alleging that SaniSure had failed to provide accurate wage statements during her second tenure. She also signaled her intent to add a derivative action under the Labor Code Private Attorney Generals Act (PAGA). SaniSure responded by submitting a “cure letter” claiming that its wage statements now comply with the Labor Code and requested that Vazquez submit her claims to binding arbitration, which Vazquez disputed.The Court of Appeal of the State of California Second Appellate District Division Six affirmed the trial court's denial of SaniSure’s motion to compel arbitration. The court found that SaniSure failed to show that Vazquez agreed to arbitrate claims arising from her second stint of employment. The court further concluded that there was no evidence of an implied agreement to arbitrate claims arising from the second employment period, as the agreement covering Vazquez’s first employment period terminated in May 2021. View "Vazquez v. SaniSure" on Justia Law

In this case, the United States Court of Appeals for the Seventh Circuit held that a potential class of consumers who purchased infant formula manufactured by Abbott Laboratories at a plant later found to be unsanitary lacked standing to sue for economic harm. This was due to their inability to demonstrate a concrete injury-in-fact, one of the three elements required for Article III standing. The plaintiffs argued that they suffered economic harm because they would not have paid the purchase price had they known the products were at a substantial risk of being contaminated. However, the court found that the plaintiffs' alleged injury was not particularized as they did not claim that the specific products they purchased were contaminated.The court compared the case to previous decisions, notably "In re Aqua Dots," where a universal defect in a product that rendered it valueless conferred standing, and "Wallace v. ConAgra Foods, Inc.," where the plaintiffs' risk of harm was considered mere speculation. The court found that the plaintiffs' claims were more similar to the latter case, as there was only a potential risk of contamination, not a universal defect. As such, the plaintiffs' claims were dismissed for lack of standing.This decision reaffirms that plaintiffs must demonstrate a concrete and particularized injury-in-fact to establish standing in federal court. Speculative or hypothetical injuries, or injuries that are not particularized because they do not affect the plaintiff in a personal and individual way, do not meet the threshold for standing. View "Economic Loss Plaintiffs v. Abbott Laboratories" on Justia Law