Justia U.S. 11th Circuit Court of Appeals Opinion Summaries

Articles Posted in Class Action
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The Eleventh Circuit Court of Appeals ruled on a class action lawsuit that involved a life insurance policy dispute between plaintiff Worth Johnson and defendant Protective Life Insurance Company. Johnson alleged that Protective breached its contract by not reassessing and adjusting its cost of insurance (COI) rates based exclusively on expectations of future mortality experience. The district court granted Protective’s motion for judgment on the pleadings, concluding that Protective did not breach its insurance contract.On appeal, the Eleventh Circuit affirmed the district court's decision in part, agreeing that the policy did not require Protective to reassess and redetermine its COI rates based exclusively on its expectations as to future mortality experience. However, the court reversed the district court's dismissal of Johnson's alternative claim that Protective did reassess and redetermine its COI rates, but ignored its expectations as to future mortality experience when doing so. The court remanded the case for further proceedings consistent with its ruling. View "Johnson v. Protective Life Insurance Company" on Justia Law

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In this case, there were three separate class action lawsuits filed against Costa Del Mar, Inc., a sunglasses manufacturer, for allegedly deceptive warranty and repair policies. Each of the named plaintiffs purchased Costa sunglasses and were charged up to $105.18 to repair their sunglasses, despite the company's lifetime warranties that they claimed required the company to repair their sunglasses either free-of-charge or for a nominal fee. The plaintiffs sought both monetary damages and injunctive relief. The district court approved a settlement agreement that provided over $32 million in monetary relief and injunctive relief. However, the United States Court of Appeals for the Eleventh Circuit vacated this decision, reasoning that the named plaintiffs lacked Article III standing to pursue injunctive relief because none of them alleged any threat of future injury. The court remanded the case back to the district court to reconsider its approval of the settlement agreement, taking into account that it could not consider the injunctive relief's value in its determination that the settlement was fair, reasonable, and adequate. View "Smith v. Miorelli" on Justia Law

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The United States Court of Appeals for the Eleventh Circuit considered whether consumers can recover statutory damages under the Fair Credit Reporting Act (FCRA) without proving actual damages caused by a consumer reporting agency's willful violation of the Act. The case was brought by plaintiffs Omar Santos and Amanda Clements on behalf of a class of individuals, against Experian Information Solutions, Inc. The plaintiffs alleged that Experian willfully violated its obligation under the FCRA to ensure consumer credit reports were prepared with maximum possible accuracy, allowing credit reports to reflect inaccurately updated status dates. The district court denied class certification, holding that the FCRA required proof of actual damages.The Eleventh Circuit vacated and remanded the district court's decision, holding that consumers do not need to prove actual damages to recover statutory damages under the FCRA. The court found that the FCRA allows consumers to recover damages of not less than $100 and not more than $1,000 for a willful violation of the Act, regardless of whether they can prove actual damages. The court cited the plain language of the Act, the structure of the statute, and the Act's legislative history in reaching its decision. The court also noted that its interpretation was consistent with the holdings of other circuit courts that have addressed this issue. The case was remanded for further proceedings consistent with this interpretation. View "Santos v. Experian Information Solutions, Inc." on Justia Law

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Mercedes-Benz USA and Daimler AG have sold and leased a number of different Mercedes-Benz vehicles painted in a color called 590 Mars Red. Either due to a defect in the paint or some other reasons the paint on some of these vehicles has deteriorated. Emily Pinon is the owner/lessee of a Mercedes-Benz vehicle painted in Mars Red. Ms. Pinon asserted numerous claims under federal and state law. The third amended class action complaint, the operative pleading, named six other individuals as plaintiffs: (collectively the “Pinon plaintiffs”). The Pinon plaintiffs submitted a motion for preliminary approval of the proposed class action settlement agreement and preliminary certification of the nationwide settlement. Collaboration between the Pinon plaintiffs and the plaintiffs in the District of New Jersey action (collectively the “Ponzio objectors”) failed. The district court rejected the contention of the Ponzio objectors that the settlement agreement failed to provide benefits to the great majority of the class members.   The Eleventh Circuit affirmed. The court held that the district court did not abuse its discretion in approving the class action settlement. The court explained that it rejects the Ponzio objectors’ argument that “the economic interests of substantial portions of the [c]lass [m]embers are in substantial conflict” and the “interests of the [Pinon] class representatives are not aligned with, and are actually antagonistic to, the interests of a majority of [c]lass [m]embers. The court explained that it was satisfied that the district court took the objections of the Ponzio objectors seriously and, after rejecting those objections, acted within its discretion in approving the settlement agreement. View "Robert Ponzio, et al v. Emily Pinon, et al v." on Justia Law

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Appellant as next of kin and on behalf of a minor, J.T.A., and all similarly situated minors (“Appellants”), filed a class action lawsuit against the School Board of Volusia County, Florida for allegedly violating the minors’ rights to free appropriate public education (“FAPE”) in violation of the Individuals with Disabilities Education Act (“IDEA”) and the Americans with Disabilities Act (“ADA”). The Appellants appealed the district court’s order dismissing their amended complaint for failure to exhaust administrative remedies under the IDEA.   The Eleventh Circuit vacated the district court’s order of dismissal and remanded the case for further proceedings consistent with the holding in Perez. The court explained that here, Appellants seek compensatory and punitive damages. The IDEA provides neither. Thus, applying Perez to this case, Appellants can proceed without attempting to exhaust administrative remedies that do not exist under the IDEA. Appellants unambiguously sought compensatory monetary damages under the ADA and not compensatory education under the IDEA. Consequently, in light of Perez, the Appellants should have been allowed to proceed with their claims regardless of the IDEA’s exhaustion requirements. View "Kimberly Powell, et al. v. School Board of Volusia County, Florida" on Justia Law

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Plaintiffs s filed a class action complaint and sought to represent a class of individuals whose Healthcare Revenue tradelines had been wrongly “re-aged” by Experian. They alleged that Experian “willfully” violated its obligation under the Fair Credit Reporting Act to “follow reasonable procedures” to ensure consumer credit reports were prepared with “maximum possible accuracy” when it allowed credit reports to reflect allegedly inaccurate status dates. The district court denied Experian’s summary judgment motion. After the close of discovery, Plaintiffs moved to certify a class of all consumers “whose Experian credit reports had an account or accounts reported by [Healthcare Revenue] with an inaccurately displayed Date of Status and were viewed by one or more third parties.” The district court adopted the magistrate judge’s recommendation and denied class certification. Plaintiffs petitioned for permission to appeal the district court’s class certification order under Rule 23(f).   The Eleventh Circuit vacated and remanded. The court held that the denial of Plaintiffs' motion for class certification was an abuse of discretion because the district court’s analysis of Rule 23(b)(3)’s predominance requirement was based on its contrary interpretation of the second option in section 1681n(a)(1)(A). The court wrote that a consumer alleging a willful violation of the Act doesn’t need to prove actual damages to recover “damages of not less than $100 and not more than $1,000.” While the parties raise other issues that may ultimately affect whether the class should be certified, the district court’s order denying class certification only relied on its interpretation of section 1681n(a)(1)(A) and didn’t address these other arguments. View "Omar Santos, et al v. Experian Information Solutions, Inc." on Justia Law

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Subscribers who bought health insurance filed a class action against Blue Cross, alleging that it violated the Sherman Antitrust Act by restricting the member plans’ ability to compete. At issue is whether the district court abused its discretion in approving a settlement agreement for a multi-district antitrust class action against the Blue Cross Blue Shield Association and its member plans.   The Eleventh Circuit affirmed. The court explained that the self-funded claimants were represented by their own counsel and class representatives in the settlement negotiations and received some compensation from the settlement. Although the settlement agreement’s allocation is facially unequal, it is not facially unfair. Further, the court held that the record supports the conclusion that the self-funded claimants and the fully insured claimants had at least potentially adverse interests. The district court did not abuse its discretion in dividing them into subclasses. Moreover, the court found that the district court also correctly applied the percentage-ofthe-fund doctrine. View "In Re: Blue Cross Blue Shield Antitrust Litigation" on Justia Law

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In January 2021, many customers of the online financial services company Robinhood were aggressively buying specific stocks known as “meme stocks” in a frenzy that generated widespread attention. Robinhood suddenly restricted its customers’ ability to buy these meme stocks (but not their ability to sell them). Some Robinhood customers who could not buy the restricted stocks brought this putative class action, seeking to represent both Robinhood customers and all other holders of the restricted meme stocks nationwide who sold the stocks during a certain period. As Robinhood customers, they allege that they lost money because Robinhood stopped them from acquiring an asset that would have continued to increase in value.   The Eleventh Circuit affirmed the district court’s dismissal of the claims. The court explained that Plaintiffs failed to state a claim. The court explained that its contract with Robinhood gives the company the specific right to restrict its customers’ ability to trade securities and to refuse to accept any of their transactions. Thus, the court wrote that because Robinhood had the right to do exactly what it did, Plaintiffs’ claims in agency and contract cannot stand. And under basic principles of tort law, Robinhood had no tort duty to avoid causing purely economic loss. View "Andrea Juncadella, et al v. Robinhood Financial LLC, et al" on Justia Law

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In August 2019, Plaintiff filed a class action against GoDaddy. The putative class alleged that the web-hosting company embarked on an unlawful telemarketing campaign. Objector-Appellant then filed an objection and moved to reconsider the fee award. He made two arguments. First, he objected that the district court awarded fees to class counsel twenty days before the court’s purported objection deadline. Second, he claimed that the parties’ settlement was a “coupon settlement” under 28 U.S.C. Section 1712(e) of the Class Action Fairness Act because GoDaddy class members could select GoDaddy vouchers as their recompense. The question at the core of this appeal is whether the plaintiffs who received a single unwanted, illegal telemarketing text message suffered a concrete injury.   The Eleventh Circuit remanded this appeal to the panel to consider the CAFA issues raised in Appellant’s appeal. The court held that the receipt of an unwanted text message causes a concrete injury. The court explained that while an unwanted text message is insufficiently offensive to satisfy the common law’s elements, Congress has used its lawmaking powers to recognize a lower quantum of injury necessary to bring a claim under the TCPA. As a result, the plaintiffs’ harm “is smaller in degree rather than entirely absent.” View "Susan Drazen, et al v. Mr. Juan Pinto" on Justia Law

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Brinker International, Inc. (“Brinker”), the owner of Chili’s restaurants, faced a cyber-attack in which customers’ credit and debit cards were compromised. Chili’s customers have brought a class action because their information was accessed (and in some cases used) and disseminated by cyber criminals. The district court certified the class, and Brinker appealed that decision. On appeal, Brinker mounted three arguments: 1) the District Court’s class certification order violates our precedent on Article III standing for class actions; 2) the district court improvidently granted certification because the class will eventually require individualized mini-trials on class members’ injuries; and 3) the district court erred by finding that a common damages methodology existed for the class.   The Eleventh Circuit vacated in part and remanded. The court explained that although all three plaintiffs adequately allege a concrete injury sufficient for Article III standing, two of the plaintiffs' allegations face a fatal causation issue. The court explained that while the district court’s interpretation of the class definitions surely meets the standing analysis, the court has outlined for one of the named plaintiffs, the court noted that the phrase in the class definitions “accessed by cybercriminals” is broader than the two delineated categories the district court gave, which were limited to cases of fraudulent charges or posting of credit card information on the dark web. Therefore, the court remanded this case to give the district court the opportunity to clarify its predominance finding. View "Eric Steinmetz, et al v. Brinker International, Inc." on Justia Law