Justia Civil Procedure Opinion Summaries

In 2015, product liability cases involving the blood-pressure medication Olmesartan were consolidated into a multidistrict litigation (MDL) in the United States District Court for the District of New Jersey. Adam Slater and his law firm, Mazie Slater Katz & Freeman, LLC, represented over 200 plaintiffs, and the case settled for over $300 million. Subsequently, Anthony Martino, a plaintiff in the MDL, filed a class action in New Jersey state court against his former lawyers, alleging they received contingent fees in violation of New Jersey court rules. The case was removed to federal court and dismissed, with the dismissal affirmed on appeal.Following this, twenty-one individuals represented by the same defendants in the MDL filed a similar action in New Jersey state court, alleging breach of contract, legal malpractice, conversion, and unjust enrichment. Defendants removed the case to the District Court, citing diversity and federal-question jurisdiction. The District Court denied the plaintiffs' motion to remand, asserting ancillary enforcement jurisdiction, and granted defendants' motion for judgment on the pleadings, applying issue preclusion. The court also dismissed the parties' motions for sanctions as moot.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that ancillary enforcement jurisdiction does not confer original jurisdiction sufficient for removal under 28 U.S.C. § 1441(a). The court also found that the plaintiffs' state-law claims did not necessarily raise a federal issue to establish federal-question jurisdiction. The court vacated the District Court's judgment and remanded the case to determine if the amount in controversy exceeded $75,000 for diversity jurisdiction. Additionally, the court vacated the order dismissing the motions for sanctions as moot, instructing the District Court to consider the merits of each motion. View "Johnson v. Mazie" on Justia Law

In this case, Columbia Legal Services represented farmworkers in a class action against Stemilt AG Services, LLC, alleging forced labor and trafficking. During the litigation, the district court issued a protective order limiting Columbia's use of discovered information outside the case. The order required Columbia to seek court approval before using any discovery materials in other advocacy efforts.The United States District Court for the Eastern District of Washington presided over the initial case. The court issued two protective orders during the discovery process. The first order protected sensitive employment data from the Washington State Employment Security Division. The second order, which is the subject of this appeal, restricted Columbia from using Stemilt's financial and employment records in other advocacy without prior court approval. The district court adopted this order to prevent Columbia from using discovered information outside the litigation, citing concerns about Columbia's intentions.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that Columbia had standing to appeal the protective order because it directly affected Columbia's ability to use discovered information in its advocacy work. The court found that the district court abused its discretion by issuing a broad and undifferentiated protective order without finding "good cause" or identifying specific harm that would result from public disclosure. The Ninth Circuit vacated the district court's protective order and remanded the case for further proceedings consistent with its opinion. The court emphasized that discovery is presumptively public and that protective orders require a showing of specific prejudice or harm. View "COLUMBIA LEGAL SERVICES V. STEMILT AG SERVICES, LLC" on Justia Law

Plaintiffs, representing a class of drivers, alleged that Progressive Specialty Insurance and Progressive Advanced Insurance systematically underestimated the actual cash value (ACV) of their totaled vehicles, thereby breaching their insurance agreements. The plaintiffs claimed that Progressive's method of calculating ACV, which included a "Projected Sold Adjustment" (PSA) to account for the fact that used cars often sell for less than their listed prices, was improper and resulted in underpayment.The United States District Court for the Eastern District of Pennsylvania certified two damages classes, finding that the plaintiffs' claims centered on the legitimacy of the PSAs and that this issue could be resolved on a class-wide basis. The court held that the plaintiffs had standing and rejected Progressive's arguments against commonality, predominance, superiority, and adequacy.The United States Court of Appeals for the Third Circuit reviewed the case and concluded that the District Court had abused its discretion in certifying the classes. The Third Circuit held that proving whether Progressive undercompensated each class member was an individual issue that could not be resolved on a class-wide basis. The court emphasized that the key issue was whether each class member received less than the true ACV of their vehicle, which would require individualized inquiries. As a result, the court found that common issues did not predominate over individual ones, and the District Court's certification of the classes was reversed and remanded for further proceedings. View "Drummond v. Progressive Specialty Insurance Co." on Justia Law

Plaintiffs filed a class action lawsuit against Kimberly-Clark Corporation, alleging that the company falsely advertised its bathroom wipes as flushable, leading consumers to pay a premium and causing plumbing damage. The parties reached a settlement where Kimberly-Clark agreed to pay up to $20 million in compensation to the class and up to $4 million in attorney’s fees. However, class members claimed less than $1 million. The district court approved the settlement under Rule 23(e) of the Federal Rules of Civil Procedure.The United States District Court for the Eastern District of New York approved the settlement, finding it fair, reasonable, and adequate. Objector Theodore H. Frank appealed, arguing that the settlement disproportionately benefited class counsel, who received most of the monetary recovery. Frank contended that the district court failed to properly assess the allocation of recovery between the class and class counsel.The United States Court of Appeals for the Second Circuit reviewed the case and agreed with Frank that the district court applied the wrong legal standard in its Rule 23(e) analysis. The appellate court clarified that Rule 23(e) requires courts to compare the proportion of total recovery allocated to the class with the proportion allocated to class counsel. The court vacated the district court’s order and judgment approving the settlement and remanded the case for further proceedings consistent with this opinion. The appellate court did not reach a conclusion on whether the settlement was fair but emphasized the need for a proper proportionality analysis. View "Kurtz v. Kimberly-Clark Corp." on Justia Law

N.S. was arrested for robbery and destruction of property and was released on his own recognizance by a Magistrate Judge. However, before he could leave the courthouse, U.S. Marshals detained him based on an ICE detainer. N.S. filed a class complaint alleging that the Marshals acted beyond their statutory authority by making a civil immigration arrest, violating the Administrative Procedure Act.The United States District Court for the District of Columbia certified the proposed class and granted N.S.'s request for a permanent injunction, prohibiting Marshal Dixon and his agents from arresting and detaining criminal defendants in the Superior Court for suspected civil immigration violations. The court held that the Marshals were not authorized to make civil immigration arrests as they had not undergone the required training. The court also found that the 2002 Order delegating authority to the Marshals lacked sufficient legal support.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Marshals were not authorized to make civil immigration arrests due to the lack of required training. However, the court found that the class-wide injunction issued by the district court was barred by 8 U.S.C. § 1252(f)(1), which prohibits lower courts from enjoining the operation of certain immigration provisions. The court vacated the injunction and remanded the case to the district court to reconsider the appropriate remedy. View "N.S. v. Dixon" on Justia Law

McKesson Corporation sent unsolicited fax advertisements to medical practices, including McLaughlin Chiropractic Associates, in 2009 and 2010. McLaughlin sued McKesson in 2014 in the U.S. District Court for the Northern District of California, alleging violations of the Telephone Consumer Protection Act (TCPA) for sending unsolicited faxes without the required opt-out notices. McLaughlin sought damages and an injunction and aimed to represent a class of fax recipients who received the advertisements on traditional fax machines or through online fax services. The District Court certified the class without distinguishing between the two methods of receipt.During the lawsuit, the Federal Communications Commission (FCC) issued the Amerifactors order, which interpreted "telephone facsimile machine" in the TCPA to exclude online fax services. The District Court, following Ninth Circuit precedent, deemed the Amerifactors order binding and granted summary judgment to McKesson for claims involving online fax services. The court then decertified the class, leaving McLaughlin with claims for only 12 faxes received on a traditional machine and damages of $6,000. The Ninth Circuit affirmed the District Court's decision.The Supreme Court of the United States reviewed the case and held that the Hobbs Act does not bind district courts in civil enforcement proceedings to an agency’s interpretation of a statute. District courts must independently determine the law’s meaning under ordinary principles of statutory interpretation while affording appropriate respect to the agency’s interpretation. The Court reversed the Ninth Circuit's decision and remanded the case for further proceedings consistent with this opinion. View "McLaughlin Chiropractic Associates, Inc. v. McKesson Corp." on Justia Law

In 2008, a class action was filed against officials from the City of Tenaha and Shelby County under 42 U.S.C. § 1983, alleging violations of the Fourth and Fourteenth Amendments. Plaintiffs claimed that the officials had an illegal practice of targeting and seizing property from racial or ethnic minorities. A settlement agreement, including a consent decree, was reached, requiring the defendants to follow specific procedures to prevent future illegal stops. The decree also included a court-appointed monitor to ensure compliance. The consent decree was initially entered in 2013, amended in 2019, and expired in July 2020. Plaintiffs' motion to extend the decree was denied, and the County Defendants settled, leaving only the City Defendants in the case.The United States District Court for the Eastern District of Texas handled the case, where class counsel filed four motions for attorney fees. The first three motions were granted, totaling $324,773.90. The fourth motion requested $88,553.33 for fees from April to December 2020. Initially denied as untimely, the decision was vacated and remanded by the appellate court. On reconsideration, the district court awarded $16,020, reducing the hourly rates and the hours deemed reasonable.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the district court failed to provide class-wide notice of the attorney-fee motion as required by Federal Rule of Civil Procedure 23(h). This failure deprived class members of the opportunity to object to the fee motion. The appellate court held that the district court abused its discretion by not enforcing the notice requirement and vacated the fee award, remanding the case for further proceedings to ensure compliance with Rule 23(h). View "Morrow v. Jones" on Justia Law

The President invoked the Alien Enemies Act (AEA) to remove Venezuelan nationals identified as members of the Tren de Aragua (TdA), a designated foreign terrorist organization. Two detainees, along with a putative class of similarly situated detainees in the Northern District of Texas, sought injunctive relief against their summary removal under the AEA. The detainees were being held in U.S. detention facilities and were notified of their imminent removal.The District Court denied the detainees' motion for a temporary restraining order (TRO) against their removal. The detainees then moved for an emergency TRO, which was not promptly addressed by the District Court. Consequently, they appealed to the Fifth Circuit, which dismissed their appeal for lack of jurisdiction and denied their motion for an injunction pending appeal, citing insufficient time given to the district court to act. The detainees also applied to the Supreme Court for a temporary injunction.The Supreme Court of the United States reviewed the case and found that the Fifth Circuit erred in dismissing the detainees' appeal for lack of jurisdiction. The Court held that the District Court's inaction had the practical effect of refusing an injunction, given the extreme urgency and high risk of irreparable harm faced by the detainees. The Supreme Court vacated the judgment of the Fifth Circuit and remanded the case for further proceedings. The Court emphasized that due process requires adequate notice and time for detainees to seek habeas relief before removal. The Government was enjoined from removing the detainees under the AEA pending further proceedings and disposition of the petition for a writ of certiorari. View "A.A.R.P. v. Trump" on Justia Law

David O’Connell filed a class action lawsuit against the United States Conference of Catholic Bishops (USCCB) for fraudulent solicitation of donations. O’Connell alleged that USCCB misled donors about the use of funds collected through the Peter’s Pence Collection, which were purportedly for emergency assistance but were instead used for investments and other purposes. O’Connell claimed that if he had known the true use of the funds, he would not have donated.The United States District Court for the District of Columbia denied USCCB’s motion to dismiss the case, which was based on the church autonomy doctrine. The District Court found that O’Connell’s claims raised a secular dispute that could be resolved using neutral principles of law, without delving into religious doctrine. The court emphasized that it would not address purely religious questions if they arose during litigation.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court dismissed USCCB’s appeal for lack of jurisdiction, stating that the collateral order doctrine did not apply. The court held that the church autonomy defense could be adequately reviewed on appeal after a final judgment, and that the denial of the motion to dismiss was not conclusive or separate from the merits of the case. The court emphasized that the church autonomy doctrine does not provide immunity from suit but serves as a defense to liability. The appeal was dismissed, and the case was remanded to the District Court for further proceedings. View "O'Connell v. United States Conference of Catholic Bishops" on Justia Law

Plaintiff filed a putative class action against the City, alleging violations of the California Public Records Act (CPRA) and the California Constitution. The City maintains a website for public records requests but the Department of Water and Power (DWP) does not provide a specific method for such requests. Plaintiff, after receiving an erroneous water bill, submitted multiple records requests through the DWP website but received no response. She later posted a complaint on social media, which led to a phone call from a customer service representative but no records were provided.The Superior Court of Los Angeles County sustained the City’s demurrer without leave to amend, concluding that the CPRA does not permit class claims and that plaintiff’s individual claim was insufficient because the City provides a method for submitting CPRA requests through its main website. The court also denied the City’s motion for sanctions, finding plaintiff’s arguments were not frivolous.The California Court of Appeal, Second Appellate District, reviewed the case. The court agreed with the trial court that the CPRA does not allow for class claims, as the statutory language and case law limit judicial relief to the individual who made the records request. However, the appellate court found that plaintiff’s individual claim was sufficient, as she alleged that she submitted a request for public records and the City failed to respond within the statutory period. The appellate court reversed the judgment and remanded with directions to enter a new order sustaining the demurrer as to the class claims and overruling the demurrer to plaintiff’s individual CPRA claim. View "Di Lauro v. City of Burbank" on Justia Law