Justia Civil Procedure Opinion Summaries

The case involves Nicholas DeFries, a former conductor for Union Pacific Railroad Company, who was removed from his duties after failing color-vision testing. Prior to DeFries' removal, a class action lawsuit had been filed against Union Pacific by a group of employees, alleging that the company's fitness-for-duty program violated the Americans with Disabilities Act (ADA). DeFries qualified as a member of this class, but the class was later narrowed and then decertified by the Eighth Circuit. DeFries subsequently filed an individual lawsuit in the District of Oregon, raising claims similar to those in the class action.The District of Oregon concluded that the commencement of the class action had tolled the statute of limitations under American Pipe & Construction Co. v. Utah, but that the tolling ended when the class definition was voluntarily narrowed, making DeFries's claim untimely. DeFries appealed this decision.The Ninth Circuit Court of Appeals reversed the district court's decision. The appellate court found ambiguity in whether the definition of the certified class included color-vision plaintiffs like DeFries. The court concluded that this ambiguity should be resolved in favor of allowing DeFries to rely on American Pipe tolling. Therefore, DeFries was entitled to tolling as a member of the class until the Eighth Circuit issued the mandate for its decision reversing class certification, making his claim timely. The case was remanded for further proceedings. View "DeFries v. Union Pacific Railroad Co." on Justia Law

A class of individuals and businesses in Northern California, who paid health insurance premiums to certain health plans, sued Sutter Health, a healthcare system operator in the region. They alleged that Sutter abused its market power to charge supracompetitive rates to these health plans, which were then passed on to the class in the form of higher premiums. The case went to trial on claims under California’s Cartwright Act for tying and unreasonable course of conduct. The jury returned a verdict in favor of Sutter.The plaintiffs appealed, arguing that the district court erred by failing to instruct the jury to consider Sutter’s anticompetitive purpose and by excluding evidence of Sutter’s conduct before 2006. The United States Court of Appeals for the Ninth Circuit agreed with the plaintiffs. It held that the district court contravened California law by removing “purpose” from the jury instructions, and that the legal error was not harmless. The court also held that the district court abused its discretion under Federal Rule of Evidence 403 in excluding as minimally relevant all evidence of Sutter’s conduct before 2006. The court concluded that these errors were prejudicial and reversed the district court’s judgment, remanding the case for a new trial. View "SIDIBE V. SUTTER HEALTH" on Justia Law

The case involves a group of former detainees at the Medium Security Institution (MSI) in St. Louis, who alleged that they were subjected to inhumane conditions in violation of the Eighth and Fourteenth Amendments. They sought to represent classes of pre-trial and post-conviction detainees, asserting that both categories of detainees were subjected to poor physical conditions and inadequate operations. After the district court denied their first motion to certify, the plaintiffs returned with new proposed classes and renewed their motion. The district court granted the renewed motion, and the City of St. Louis appealed.The district court had initially denied the plaintiffs' motion to certify four classes, citing the open-ended class periods and the City's undisputed improvements to conditions at MSI over time. However, the court suggested that a more focused claim covering a more discrete time period and a more uniform class might be appropriate for class certification. In response, the plaintiffs filed a renewed motion for class certification, proposing four new, more narrowly defined classes. The district court granted the renewed motion, certifying the four new classes.The City of St. Louis appealed the district court's decision to the United States Court of Appeals for the Eighth Circuit, challenging both the decision to certify the classes and several of its procedural aspects. The appellate court reversed the certification of the classes and remanded the case for further proceedings. The court found that the district court had abused its discretion in certifying the classes, as the classes were not "sufficiently cohesive to warrant adjudication by representation." The court also found that the district court had erred in describing the standard for liability and had failed to conduct a rigorous analysis of the requirements for class certification. View "Cody v. City of St. Louis" on Justia Law

This case involves a dispute between a lawyer, George Fleming, and his former clients, referred to as the "Wilson plaintiffs". Fleming had represented over 8,000 plaintiffs in a mass-tort action against the manufacturer of a diet pill known as "fen-phen". The Wilson plaintiffs are about 4,000 of Fleming’s former clients. Fleming had spent roughly $20 million to medically screen over 40,000 potential claimants, about 20% of whom became his clients. In 2006, Fleming settled the case for $339 million and reimbursed himself for the costs of the screenings by deducting that amount from the settlement funds. He charged his clients not just for their own medical-screening costs but also for those of approximately 32,000 people who never became his clients and who did not participate in the underlying case. This financial choice led to further litigation, with Fleming as the defendant in various actions brought by his former clients.In the lower courts, Fleming successfully opposed a motion for class certification in a federal court case brought by two of his former clients, arguing that the claims of his former clients were not sufficiently common for aggregate treatment. After the denial of class certification, another group of about 650 former clients sued Fleming for breaches of contract and fiduciary duty. Following a verdict against Fleming in this case, the Wilson plaintiffs moved for summary judgment on the ground that the verdict collaterally estopped Fleming from contesting the merits of their claims against him. Fleming successfully opposed that motion, arguing that the issues presented by the other plaintiffs were not identical to those of the Wilson plaintiffs. The trial court denied the Wilson plaintiffs’ motion for summary judgment without explanation. Later, Fleming moved for summary judgment, asserting defensive collateral estoppel against the Wilson plaintiffs.The Supreme Court of Texas affirmed the judgment of the court of appeals, but for a different reason. The court concluded that Fleming was judicially estopped from establishing an essential component of his summary-judgment motion. The court found that Fleming's assertions in prior litigation clearly and unequivocally contradicted his summary-judgment motion’s assertions regarding whether the Wilson plaintiffs’ legal and factual positions were materially identical to those of the other plaintiffs. The court held that Fleming was estopped from asserting that the thousands of remaining plaintiffs’ claims were materially indistinguishable. View "FLEMING v. WILSON" on Justia Law

The case involves plaintiffs Christopher Maia and Sean Howarth, who were employed as laborers for defendant IEW Construction Group. The company required them to perform “pre-shift” and “post-shift” work, for which they were not paid. Both Maia and Howarth were laid off in November 2021. In April 2022, they filed a class action complaint alleging that IEW violated the Wage Payment Law (WPL) and the Wage and Hour Law (WHL).The trial judge held that Chapter 212, which amended the WPL and WHL, does not apply retroactively and thus dismissed plaintiffs’ claims for conduct that arose prior to Chapter 212’s effective date of August 6, 2019. The Appellate Division reversed this decision.The Supreme Court of New Jersey granted leave to appeal. The court held that Chapter 212 is to be applied prospectively to conduct that occurred on or after August 6, 2019, not retroactively to conduct that occurred before that date. The trial judge properly dismissed the portions of the complaint relying on Chapter 212 but arising from conduct prior to its effective date. The court reversed the Appellate Division’s judgment, reinstated the trial judge’s order partially dismissing plaintiffs’ complaint, and remanded for further proceedings. View "Maia v. IEW Construction Group" on Justia Law

The case revolves around a data privacy dispute involving Pebbles Martin and LCMC Health Holdings and Louisiana Children’s Medical Center (collectively, “LCMC”). Martin filed a class action suit alleging that LCMC violated Louisiana law by embedding tracking pixels onto its website that shared her private health information with third-party websites. The question before the court was not to determine the merits of Martin’s claims, but instead to determine which forum—state or federal—is proper to hear this dispute. LCMC argued that the suit should proceed in federal court because it acted under the direction of a federal officer when it allegedly violated Louisiana law. Martin, however, argued that the suit should remain in state court because LCMC fails to show a basis for federal jurisdiction.LCMC had removed the case to federal court, invoking the federal officer removal statute as the basis for jurisdiction. Martin moved to remand to state court, and the district court granted Martin’s motion, holding that LCMC did not act under the direction of a federal officer when it disclosed private health information to third-party websites. LCMC appealed the remand order.The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court concluded that LCMC did not act under the direction of a federal officer when it embedded tracking pixels onto its website. The court noted that a hospital does not act under the direction of the federal government when it maintains an online patient portal that utilizes tracking pixels. Therefore, the federal officer removal statute does not provide jurisdiction for this case to be heard in federal court. The court affirmed the district court’s order remanding this case to state court. View "Martin v. LCMC Health Holdings" on Justia Law

The case revolves around an oil spill caused by Plains All American Pipeline, L.P. (Plains). The spill resulted in the unlawful discharge of over 142,000 gallons of crude oil into the ocean and onto a beach. The trial court considered restitution for four groups of claimants who alleged losses due to the spill. The People of the State of California appealed the denial of restitution for claimants in two of these groups.The trial court had previously ruled that oil industry claimants were not direct victims of Plains' crimes and accepted mediated settlements in lieu of restitution. It also denied restitution to fishers based on a pending class action lawsuit, declined to consider aggregate proof presented by fishers, and refused to consider Plains' criminal conduct.The Court of Appeal of the State of California Second Appellate District Division Six held that restitution could not be denied based on mediated civil settlements or a class action lawsuit. However, it upheld the trial court's decision to deny restitution to fishers and oil industry workers, stating that they were not direct victims of the pipeline shutdown after the spill. The court remanded the case for consideration of restitution for four fisher claims, but in all other respects, it affirmed the trial court's decision and denied the writ petition. View "People v. Plains All American Pipeline, L.P." on Justia Law

The case originated as a class action dispute about the underpayment of oil and gas royalties due on wells in Oklahoma. The plaintiff, Chieftain Royalty Company, sued SM Energy Company, the operator of the wells, under various tort theories, including fraud, breach of contract, and breach of fiduciary duty. In 2015, the claims were settled for approximately $52 million. Following the settlement, Chieftain's counsel moved for attorneys’ fees, and Chieftain sought an incentive award for its CEO, Robert Abernathy. Two class members objected to the awards and appealed. The court affirmed the settlement but reversed the attorneys’ fees and incentive awards, remanding to the district court for further proceedings.On remand, the district court re-awarded the fees and incentive award. The class did not receive notice of the 2018 attorneys’ fees motion as required under Federal Rule of Civil Procedure 23(h)(1), so the court vacated the district court order awarding attorneys’ fees and remanded with instructions to direct class-wide notice of the 2018 attorneys’ fees motion and to re-open the period for objections. The court did not reach the merits of the appellate challenge to the re-awarded attorneys’ fees. The court affirmed the district court’s incentive award to Mr. Abernathy. View "Chieftain Royalty Company v. SM Energy Company" on Justia Law

The case involves Karen Frohn, who applied for and received a life insurance policy from Globe Life and Accident Insurance Company on behalf of her husband, Greg Frohn. After Greg's death, Karen submitted a claim for death benefits, which Globe denied. Karen then sued Globe, both individually and on behalf of a putative class of beneficiaries, challenging the denial of her claim.Globe moved for summary judgment, arguing that it was entitled to rescind the life insurance policy because Karen was not truthful in her application for insurance. The district court granted Globe’s motion, barring Karen from recovery on her claims against Globe. Karen also asked the court to redact certain portions of that order, but the district court published it without any redactions. Karen appealed these decisions.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that Karen had voluntarily waived her husband's physician-patient privilege by signing an Authorization for Release, allowing Globe to access Greg's medical records. The court also found that Globe was entitled to rescind the policy under Ohio law because Karen had made material misrepresentations in the insurance application. The court concluded that Globe's defense barred Karen's breach-of-contract and bad-faith claims. View "Frohn v. Globe Life and Accident Ins Co" on Justia Law

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