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

Three healthcare providers filed a class action against Progressive over a claims-handling process that was allegedly illegal under Florida law. The district court certified an injunction class under Federal Rule of Civil Procedure 23(b)(2), but declined to certify a damages class under Rule 23(b)(3).The Eleventh Circuit held that the district court erred by certifying the injunction class, because the injunctive remedy the class sought -- in this case, damages -- was improper. Therefore, Rule 23(b)(3) is the proper mechanism for certifying a damages class. The court stated that, because plaintiffs' damages claims involved individualized issues that ruled out Rule 23(b)(3) certification, plaintiffs sought to recast their claims as one for injunctive relief under Rule 23(b)(2). View "AA Suncoast Chiropractic Clinic, P.A. v. Progressive American Insurance Co." on Justia Law

The parties appealed the district court's award of attorney's fees in a class action settlement brought by banks against Home Depot to recover resulting losses from a data breach.The Eleventh Circuit held that this was a contractual fee-shifting case, and the constructive common-fund doctrine did not apply. The court held that the district court erred by enhancing class counsel's lodestar based on risk; the district court did not abuse its discretion in compensating class counsel for time on the card-brand recovery process and for time spent finding and vetting class representatives; and there was no merit to Home Depot's contention that the district court's order did not allow for meaningful review. The court also held that the district court properly excluded attorney's fees from the class benefit, and the district court did not abuse its discretion by including the $14.5 million premiums in the class benefit. Accordingly, the court affirmed in part, vacated in part, and remanded. View "Northeastern Engineers Federal Credit Union v. Home Depot, Inc." on Justia Law

The Eleventh Circuit held that the district court correctly determined that the availability of class arbitration was a question of arbitrability, presumptively for the court to decide, because it was the kind of gateway question that determined the type of dispute that would be arbitrated. In this case, defendants sought to compel arbitration on a class basis with JPay, a Miami-based company that provides fee-for-service amenities in prisons in more than thirty states.The court held, however, that the language the parties used in their contract expressed their clear intent to overcome the default presumption and to arbitrate gateway questions of arbitrability, including the availability of class arbitration. Therefore, the court vacated the district court's grant of summary judgment to JPay, reversed the denial of defendants' motion to compel arbitration, and remanded for further proceedings. View "JPay, Inc. v. Kobel" on Justia Law

In Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338 (2011), the Supreme Court reversed the certification of a nationwide class of female Wal-Mart employees claiming gender discrimination. The unnamed plaintiffs in Dukes then filed new actions seeking certifications of regional classes. A group of would-be class members of one of these regional class actions, appealed the district court's dismissal of the class claims and the denial of appellants' motion to intervene. The Eleventh Circuit held that the appeal from the order dismissing the class claims was untimely filed, and was therefore jurisdictionally barred, and the appeal from the order denying appellants' motion to intervene was moot. View "Love v. Wal-Mart Stores, Inc." on Justia Law

Plaintiffs filed a class action in state court claiming that the City of Montgomery's red-light program and fines violated state law. City and Traffic Solutions removed to federal court under the Class Action Fairness Act, 28 U.S.C. 1332(d), but the district court remanded to state court. After determining that it had jurisdiction over the appeal, the Eleventh Circuit held that the home state exception to CAFA jurisdiction was applicable in this case where the only primary defendant was a citizen of the state in which the action was originally filed and other requirements under the statute were met. Accordingly, the court affirmed the judgment. View "Hunter v. City of Montgomery, Alabama" on Justia Law

Plaintiffs filed suit alleging that defendants operated a racketeering enterprise through which they performed and billed for unnecessary heart procedures. The district court dismissed the case. At issue on appeal was whether the Class Action Fairness Act's local-controversy provision, (CAFA), 28 U.S.C. 1332(d)(4), precluded the district court from exercising federal-question jurisdiction. If not, the court must decide whether plaintiffs alleged that they were injured in their "business or property," under the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. 1964(c). The court affirmed the denial of plaintiffs' motion to remand because CAFA's local-controversy provision does not prohibit district courts from exercising federal-question jurisdiction under 28 U.S.C. 1331. However, the court vacated the district court's grant of defendants' motion to dismiss because plaintiffs alleged economic injuries that were recoverable under RICO. View "Blevins v. Seydi V. Aksut, M.D." on Justia Law

Wright filed suit in federal court against Pilot, alleging that Pilot and certain Pilot employees systematically shortchanged some trucking companies with whom Pilot had discount agreements by failing to give them the agreed-upon benefits. Wright filed claims under both state and federal law. At issue here is whether federal courts that are given original subject-matter jurisdiction over state-law claims by the Class Action Fairness Act (CAFA), 28 U.S.C. 1332(d), retain that jurisdiction even when the class claims are dismissed before the class is certified. The district court found that CAFA does not vest the federal courts with original jurisdiction over state-law claims after the class claims are dismissed. Pilot argues that CAFA conferred original jurisdiction over all of Wright’s claims at the time Wright filed them, such that the jurisdiction could not have divested when the class claims were later dismissed. Here, Wright first filed directly in federal court under CAFA but now wishes to refile in state court. When the post-filing action that did away with the class claims is not an amendment to the complaint, the court saw no basis for distinguishing cases originally filed in federal court under CAFA from those removed to federal court. Therefore, the court concluded that CAFA continues to confer original federal jurisdiction over the remaining state-law claims in this suit. Because CAFA vested the district court with original jurisdiction over the remaining claims, there was no need for it to analyze supplemental jurisdiction. Accordingly, the court reversed and remanded. View "Wright Transportation, Inc. v. Pilot Corporation" on Justia Law

General Motors challenged the district court's order granting in part a motion for class certification in an action brought by plaintiffs under the Florida Deceptive and Unfair Trade Practices Act (FDUTPA), Fla. Stat. 501.201 et seq. The district court certified a class consisting of all Florida purchasers and lessees of 2014 Cadillac CTS sedans. In this case, the district court found the predominance requirement to be satisfied by an essential question common to each class member: whether the inaccurate Monroney sticker provided by General Motors constituted a misrepresentation prohibited by FDUTPA. The court concluded that, by inaccurately communicating that the 2014 Cadillac CTS had attained three perfect safety ratings, General Motors plainly obtained enhanced negotiating leverage that allowed it to command a price premium. The size of that premium represents the damages attributable to that theory of liability. Because that theory is consistent for all class members, the predominance requirement under Federal Rule of Civil Procedure 23(b)(3) is satisfied. This consistency is also sufficient to establish the commonality requirement under Rule 23(a)(2). Because common questions of law and fact predominate, class-wide adjudication appropriately conserves judicial resources and advances society’s interests in judicial efficiency. Finally, the court rejected General Motor's contention that plaintiff failed to prove that she can fairly and adequately protect the interests of the class. Because the district court did not abuse its discretion in certifying the class, the court affirmed the judgment. View "Carriuolo v. General Motors Co." on Justia Law

Plaintiffs, consumers from California and Texas, filed class actions against Electrolux, the manufacturer of front-loading washing machines, alleging warranty and consumer claims. Specifically, plaintiffs allege that the rubber seal on the front door of the machines retains water, allowing mildew to grow, causing stains on clothing, and creating a foul odor. The court concluded that the district court abused its discretion in assessing predominance and therefore vacated the class certification. On remand, the district court should revisit Electrolux's argument that the consumer claims do not satisfy predominance because plaintiffs cannot prove causation on a classwide basis, and the district court abused its discretion by certifying the warranty claims without first resolving preliminary questions of state law that bear on predominance. The court further concluded that plaintiffs' damages do not necessarily defeat predominance, and Electrolux's defense of misuse does not necessarily defeat predominance. Accordingly, the court vacated and remanded. View "Brown v. Electrolux Home Products, Inc." on Justia Law

Aero filed a class action in Florida state court in 2010 against defendants, alleging that defendants sent unsolicited facsimile advertisements to the putative class in violation of the Telephone Consumer Protection Act (TCPA), 47 U.S.C. 227(b)(1)(C). These claims concern conduct that took place in 2006 and are governed by a four-year statute of limitations. The Florida state court granted summary judgment in favor of defendants in 2013. Later that year, Ewing filed a similar class complaint in federal court against the same defendants containing similar allegations. Recognizing that more than four years had passed since the alleged conduct, the complaint alleges that the statute of limitations was tolled during the pendency of Aero’s purported class action. The court affirmed, under Griffin v. Singletary, the district court's judgment, concluding that the pendency of Aero's purported class action did not toll the statute of limitations for Ewing's purported class action. View "Ewing Indus. Corp. v. Bob Wines Nursery, Inc." on Justia Law