Justia Class Action Opinion Summaries

Plaintiffs initiated a class action against National General Insurance Company and Integon National Insurance Company, alleging that the defendants improperly denied their car accident claims and rescinded their automobile insurance policies. The plaintiffs claimed that the defendants retroactively denied insurance claims and rescinded policies based on the plaintiffs' failure to disclose household members. The plaintiffs sought class certification for 1,032 insureds who had their policies rescinded under similar circumstances.The Superior Court of San Bernardino County denied the plaintiffs' motion for class certification, citing the lack of a palpable trial plan for resolving damages. The court noted that the plaintiffs admitted most of the available damages were inherently individualized and expressed concern that the plaintiffs wanted to make the case more manageable by forfeiting certain categories of damages. The court concluded that class treatment would not be a substantial benefit to the litigants.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The appellate court disagreed with the defendants' contention that common questions of law and fact did not predominate on the issue of liability. The court found that the trial court had relied on improper legal criteria by denying certification based on individualized damages and by not considering the potential benefits of class certification. The appellate court held that individualized proof of damages does not preclude class certification when common issues of liability predominate. The court reversed the order denying class certification and remanded the case, directing the trial court to certify, at minimum, a liability-only class and to consider whether any subclasses are necessary. View "Cobos v. National General Insurance Co." on Justia Law

Heather Schroeder and Misty Tanner, representing a class of Indiana car owners insured by Progressive Paloverde Insurance Company and Progressive Southeastern Insurance Company, filed a lawsuit claiming that Progressive breached its contractual duty by applying "Projected Sold Adjustments" to the list prices of comparable cars when determining the actual cash value of totaled cars. The insurance policy in question specifies that the actual cash value is determined by the market value, age, and condition of the vehicle at the time of the loss.The United States District Court for the Southern District of Indiana, Indianapolis Division, recognized that whether Progressive paid each class member the actual cash value of their car is not susceptible to classwide proof. However, it concluded that common evidence could establish that Progressive employed an unacceptable method for calculating actual cash value payments by applying Projected Sold Adjustments. The court certified a class on this basis.The United States Court of Appeals for the Seventh Circuit reviewed the case and concluded that Progressive’s policy does not preclude the use of Projected Sold Adjustments in calculating actual cash value payments, as long as the insureds are ultimately paid the actual cash value of their totaled cars as defined under the policy and Indiana law. The court found that individual questions about whether Progressive failed to pay each class member the actual cash value of their car would overwhelm any common ones. Consequently, the Seventh Circuit reversed the district court’s class certification decision and remanded the case for further proceedings. View "Schroeder v. Progressive Paloverde Insurance Co." on Justia Law

Lisa Bodenburg, an Apple customer, purchased a 200 GB iCloud data storage plan, expecting it to add to the 5 GB of free storage she already had, resulting in a total of 205 GB. When she discovered that the plan only provided 200 GB in total, she filed a putative class action against Apple, alleging breach of contract and violations of California’s consumer protection laws due to Apple’s allegedly deceptive representations about its iCloud storage plans.The United States District Court for the Northern District of California dismissed Bodenburg’s action with prejudice. The court found that Bodenburg could not state a claim for breach of contract because Apple had fulfilled its contractual obligations by providing the additional storage as described in the iCloud Legal Agreement. The court also found that Bodenburg’s claims under California’s consumer protection laws did not satisfy the “reasonable consumer” test or the heightened pleading standard of Fed. R. Civ. P. 9(b).The United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The panel held that Bodenburg could not state a claim for breach of contract because the iCloud Legal Agreement did not promise an additional 200 GB of storage but rather additional storage, which Apple provided. The court also held that Bodenburg’s claims under California’s consumer protection laws failed the reasonable consumer test, as Apple’s statements were not misleading when considered in context. Additionally, the claims did not meet Rule 9(b)’s heightened pleading requirements because Bodenburg could not demonstrate that Apple’s statements were false or deceptive. Thus, the dismissal of Bodenburg’s action was affirmed. View "Bodenburg v. Apple, Inc." on Justia Law

Linda Martin filed a class action lawsuit against the FBI, alleging that the Notice of Seizure provided to property owners did not meet the Due Process requirements under the Fifth Amendment. The FBI had seized $40,200 from Martin's safe deposit box and issued a Notice of Seizure, which Martin claimed lacked specific legal or factual bases for the seizure, thus denying her a meaningful opportunity to respond. Martin sought declaratory and injunctive relief for herself and a proposed nationwide class of individuals who had received similar notices.The United States District Court for the District of Columbia dismissed Martin's individual claim as moot after the FBI returned her seized property. The court also dismissed the class action for failure to exhaust administrative remedies and for failure to state a plausible Due Process claim. The court found that Martin had an adequate opportunity to present her Due Process challenge during the administrative proceedings and that her claim was moot because the FBI had returned her property.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court affirmed the district court's dismissal of Martin's individual claim as moot, as the FBI had returned her property. The court also dismissed the appeal of the class certification judgment for lack of jurisdiction, noting that Martin had not challenged the denial of class certification in her appellate briefs. The court concluded that without a certified class, it lacked jurisdiction to review the district court's merits rulings on the Due Process and exhaustion claims. View "Martin v. FBI" on Justia Law

Eight citizens of Mali alleged that, as children, they were trafficked to Côte d’Ivoire and forced to work without pay on small, remote cocoa farms. After eventually returning to Mali, they brought a putative class action in the United States against seven major cocoa importers, claiming the companies violated the Trafficking Victims Protection Reauthorization Act (TVPRA) by knowingly benefiting from a supply chain that relied on forced child labor. The plaintiffs asserted that the importers orchestrated and controlled a cocoa supply chain “venture” and delayed meaningful action against child labor through their leadership of the World Cocoa Foundation.The United States District Court for the District of Columbia dismissed the complaint for lack of standing. The court found that the plaintiffs failed to connect the defendants to any specific cocoa plantations, including those where the plaintiffs had worked. The court concluded that the plaintiffs’ general, industry-wide allegations lacked the specificity required to establish causation under Article III of the Constitution. The plaintiffs appealed, and the United States Court of Appeals for the District of Columbia Circuit held the appeal in abeyance pending resolution of a similar case, Doe 1 v. Apple Inc.The United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s dismissal. The appellate court held that the plaintiffs lacked Article III standing because they did not plausibly allege facts showing a causal connection between their forced labor and the importers’ conduct. Specifically, the complaint failed to allege that the importers sourced cocoa, directly or through intermediaries, from the specific farms where the plaintiffs worked. The court distinguished this case from Doe 1 v. Apple Inc., where plaintiffs had plausibly traced their injuries to the defendants’ suppliers. The dismissal was affirmed. View "Coubaly v. Cargill Incorporated" on Justia Law

Adam Steele and Krystal Comer, tax return preparers, challenged the IRS's requirement to obtain or renew a Preparer Tax Identification Number (PTIN) by completing Form W-12, which involves paying a fee and disclosing personal information. They initially joined a class action in 2014 contesting the IRS's authority to impose these fees and the amount of information required by Form W-12. However, class counsel later withdrew these claims. Steele and Comer then attempted to revive these claims in a separate lawsuit.The United States District Court for the District of Columbia dismissed their complaint, citing the rule against claim-splitting, which prevents duplicative litigation between the same parties asserting the same claims, even without a final judgment in the first case. The district court found that Steele and Comer had already raised and then withdrawn these claims in the ongoing class action and were denied leave to amend the complaint to reassert them.On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the district court's dismissal. The appellate court held that the Paperwork Reduction Act (PRA) does not bar judicial review of the IRS's authority to demand information through Form W-12, but the rule against claim-splitting still precludes the plaintiffs' suit. The court emphasized that claim-splitting bars duplicative litigation filed before final judgment and that Steele and Comer had a fair opportunity to litigate their claims in the earlier class action. The court concluded that the district court's dismissal was proper to prevent strategic end runs around procedural rulings and to preserve the integrity of the adjudicative process. View "Steele v. United States" on Justia Law

The plaintiffs, Cynthia Wilson, Erin Angelo, and Nicholas Angelo, filed a class action lawsuit against Centene Management Company, L.L.C., Celtic Insurance Company, Superior HealthPlan, Inc., and Centene Company of Texas, L.P. They alleged that the defendants provided materially inaccurate provider lists for their health insurance plans, causing the plaintiffs and proposed class members to pay inflated premiums. Specifically, the plaintiffs claimed that the inaccuracies in the provider directories led to overcharges for access to healthcare providers who were not actually available.The United States District Court for the Western District of Texas denied class certification, concluding that the plaintiffs lacked standing because they failed to establish an injury-in-fact. The court found that the plaintiffs did not adequately demonstrate that they had reasonable expectations regarding the size of the provider network and that the premiums they paid were inflated due to discrepancies between the promised and actual network sizes. The court also questioned the plaintiffs' expert report, which attempted to show a correlation between network size and premium prices, stating that it only showed correlation, not causation.The United States Court of Appeals for the Fifth Circuit reviewed the case and determined that the district court erred by not considering the appropriate test for determining standing at the class-certification stage. The Fifth Circuit adopted the class-certification approach, which requires only that the named plaintiffs demonstrate individual standing before addressing class certification under Rule 23. The appellate court found that the district court improperly engaged in a merits-based evaluation of the plaintiffs' expert testimony when determining standing. The Fifth Circuit vacated the district court's order denying class certification and remanded the case for further proceedings consistent with its opinion. View "Wilson v. Centene Management" on Justia Law

Eugene Westmoreland, an Illinois inmate who uses a wheelchair, filed a class action lawsuit seeking prospective relief to make the showers at the Northern Reception and Classification Center (NRC) accessible. He claimed the showers were inaccessible to individuals using mobility aids. Westmoreland filed the suit without first using the prison's internal grievance process as required by the Prison Litigation Reform Act (PLRA). Six weeks after filing, he was transferred to a different facility with accessible showers, which led to questions about the mootness of his claim.The United States District Court for the Northern District of Illinois dismissed Westmoreland's suit for lack of subject matter jurisdiction, finding his claim moot due to his transfer. The court also determined that no exception to mootness applied, as Westmoreland had not exhausted the internal grievance process, making him an inadequate class representative.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that Westmoreland's transfer rendered his claim moot and that he did not qualify for any exceptions to mootness. The court also found that Westmoreland's failure to exhaust the grievance process as required by the PLRA made him an inadequate class representative, preventing the class action from proceeding. Consequently, the court affirmed the dismissal of the suit. View "Westmoreland v. Hughes" on Justia Law

Anthony Rojas, a student at the University of Florida, filed a class action lawsuit against the University of Florida Board of Trustees. Rojas claimed that the University breached its contract by suspending on-campus services and closing facilities during the COVID-19 pandemic, despite students being required to pay mandatory fees for these services. He also alleged that the University failed to refund these fees. The complaint included a spring 2020 tuition statement, a general statement of tuition and fee estimates for the 2019-2020 academic year, and the University’s financial liability agreement.The trial court dismissed the unjust enrichment claim but denied the University’s motion to dismiss the breach of contract claim, ruling that the complaint adequately pleaded the existence of an express contract. The University appealed, and the First District Court of Appeal reversed the trial court’s decision, holding that the claims were barred by sovereign immunity. The First District concluded that the contract alleged by Rojas did not constitute an express written contract sufficient to overcome sovereign immunity.The Supreme Court of Florida reviewed the case and quashed the First District’s decision. The Court held that the waiver-by-contract doctrine does not preclude claims based on the breach of implied covenants or conditions that do not conflict with express contract provisions. The Court found that the First District erred in requiring extraordinary specificity in government contracts and in failing to recognize permissible implied covenants. The case was remanded for further proceedings consistent with this opinion. View "Rojas v. University of Florida Board of Trustees" on Justia Law

Plaintiffs, who owned real property in Southfield, Michigan, became delinquent on their property taxes between 2012 and 2014. Oakland County foreclosed on their properties under the General Property Tax Act (GPTA). The plaintiffs had the opportunity to redeem their properties by paying the delinquent taxes, but they failed to do so. Consequently, the properties were foreclosed, and the city of Southfield exercised its right of first refusal to purchase the properties for the minimum bid, which included the unpaid taxes and associated fees. The properties were then conveyed to the Southfield Neighborhood Revitalization Initiative (SNRI).The plaintiffs filed a class action lawsuit in the Oakland Circuit Court, alleging violations of their constitutional rights, including the Takings Clauses of the Michigan and United States Constitutions. The trial court granted summary disposition in favor of the defendants, citing lack of jurisdiction, lack of standing, and res judicata. The Michigan Court of Appeals affirmed the trial court's decision. However, the Michigan Supreme Court vacated the Court of Appeals' decision and remanded the case for reconsideration in light of its decision in Rafaeli, LLC v Oakland Co, which held that retaining surplus proceeds from tax-foreclosure sales violated the Takings Clause of the Michigan Constitution.On remand, the trial court again granted summary disposition to the defendants, but the Court of Appeals reversed in part, holding that Rafaeli applied retroactively and that the plaintiffs had valid takings claims. The Michigan Supreme Court reviewed the case and held that a taking occurs when a governmental unit retains property without offering it for public sale and the value of the property exceeds the amount owed in taxes and fees. The Court also held that MCL 211.78m, as amended, applies prospectively, while MCL 211.78t applies retroactively but does not govern this case. The case was remanded to the trial court for further proceedings. View "Jackson v. Southfield Neighborhood Revitalization Initiative" on Justia Law