Justia U.S. 9th Circuit Court of Appeals Opinion Summaries
Articles Posted in Class Action
PIMENTEL V. CITY OF LOS ANGELES
The case involves a class action lawsuit against the City of Los Angeles, challenging the constitutionality of a $63 late fee imposed for failing to pay a parking meter fine within 21 days. The plaintiffs argue that this late fee, which matches the amount of the original fine, violates the Eighth Amendment's Excessive Fines Clause. The plaintiffs incurred at least one parking meter citation and late fee, and they assert that the late fee is both facially unconstitutional and unconstitutional as applied to individuals who cannot afford to pay it within the specified time frame.The United States District Court for the Central District of California initially granted summary judgment in favor of the City, finding that the $63 parking fine was not "grossly disproportionate" to the offense of overstaying a parking meter. The court also rejected the challenge to the $63 late fee without providing a detailed rationale. The plaintiffs appealed, and the Ninth Circuit previously upheld the initial fine but remanded the case to determine whether the late fee violated the Excessive Fines Clause.The United States Court of Appeals for the Ninth Circuit reversed the district court's summary judgment for the City regarding the late fee. The Ninth Circuit found that a genuine factual dispute exists about the City's basis for setting the late fee at 100 percent of the parking fine. The court noted that the City provided no evidence on how it determined the $63 late fee amount, making it impossible to conclude as a matter of law that the fee is not "grossly disproportional" to the harm caused by the untimely payment. The court declined to incorporate means-testing into the Excessive Fines Clause analysis, rejecting the plaintiffs' argument that the fee should consider individuals' ability to pay. The case was remanded for further proceedings consistent with this opinion. View "PIMENTEL V. CITY OF LOS ANGELES" on Justia Law
HOUSTON V. MARICOPA COUNTY
Brian Houston, representing a putative class, filed a lawsuit against Maricopa County and Sheriff Paul Penzone, alleging that the County's practice of posting arrestees' photographs and identifying information on its Mugshot Lookup website violated his substantive and procedural due process rights and his right to a speedy public trial. Houston's mugshot and personal details were posted online for three days following his arrest, even though he was never prosecuted. He claimed this caused him public humiliation, reputational harm, and emotional distress.The United States District Court for the District of Arizona dismissed Houston's claims. The court found that the Mugshot Lookup post was not a condition of pretrial detention and that Houston failed to show a cognizable liberty or property interest under state law for his procedural due process claim. The court also dismissed his Sixth Amendment claim, noting that Houston was not prosecuted and thus had no trial.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court's dismissal of Houston's substantive due process claim, holding that Houston sufficiently alleged that the Mugshot Lookup post caused him actionable harm and that the County's transparency justification did not rationally relate to the punitive nature of the post. The court affirmed the dismissal of Houston's procedural due process claim, as he did not demonstrate a protected liberty or property interest under state law. The court also affirmed the dismissal of his Sixth Amendment claim, as Houston was not prosecuted and thus had no right to a speedy trial.The Ninth Circuit concluded that Houston adequately pleaded a substantive due process claim but failed to state claims for procedural due process and Sixth Amendment violations. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "HOUSTON V. MARICOPA COUNTY" on Justia Law
BLACK LIVES MATTER LOS ANGELES V. CITY OF LOS ANGELES
In the wake of George Floyd's death in May 2020, Los Angeles experienced widespread protests. The plaintiffs, including Black Lives Matter Los Angeles and several individuals, filed a class action lawsuit against the City of Los Angeles and then-LAPD Chief Michel Moore. They alleged that the LAPD used excessive force, arrested protestors without probable cause, and restricted their First Amendment rights. The lawsuit sought to certify four classes: a Direct Force Class, an Arrest Class, an Infraction Class, and an Injunctive Relief Class.The United States District Court for the Central District of California certified all four classes. The court found that the plaintiffs had raised common questions about whether LAPD customs or policies caused their injuries. However, the district court did not rigorously analyze whether the damages classes satisfied the commonality requirement under Rule 23(a) or whether common questions predominated over individual ones under Rule 23(b)(3). The court also failed to address whether the Injunctive Relief Class met the commonality requirement under Rule 23(a).The United States Court of Appeals for the Ninth Circuit vacated the district court’s class certification order. The Ninth Circuit held that the district court did not rigorously analyze whether the plaintiffs produced sufficient evidence to meet the class certification requirements. Specifically, the district court did not adequately address the commonality and predominance requirements for the damages classes or identify common questions for the Injunctive Relief Class. The Ninth Circuit remanded the case with instructions for the district court to fully address Rule 23’s class certification requirements. View "BLACK LIVES MATTER LOS ANGELES V. CITY OF LOS ANGELES" on Justia Law
LYTLE V. NUTRAMAX LABORATORIES, INC.
Plaintiffs, dog owners, alleged that Nutramax Laboratories falsely marketed their product, Cosequin, as promoting healthy joints in dogs, despite evidence suggesting it provided no such benefits. They claimed this violated the California Consumers Legal Remedies Act (CLRA). The district court certified a class of California purchasers who were exposed to the allegedly misleading statements on Cosequin’s packaging.The United States District Court for the Central District of California certified the class, relying on the proposed damages model of Plaintiffs’ expert, Dr. Jean-Pierre Dubé, who had not yet executed his model. Nutramax challenged this, arguing that the model needed to be applied to the class to demonstrate that damages were susceptible to common proof. The district court found Dr. Dubé’s model sufficiently reliable for class certification purposes and concluded that common questions predominated regarding injury. Nutramax also contended that the element of reliance was not susceptible to common proof, but the district court found that classwide reliance could be established through proof of material misrepresentation.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The court held that there is no general requirement for an expert to apply a reliable damages model to the proposed class to demonstrate that damages are susceptible to common proof at the class certification stage. The court concluded that the district court did not abuse its discretion in finding Dr. Dubé’s proposed model sufficiently sound. Additionally, the court rejected Nutramax’s argument regarding reliance, affirming that classwide reliance could be established under the CLRA through proof of material misrepresentation. The Ninth Circuit affirmed the district court’s grant of class certification. View "LYTLE V. NUTRAMAX LABORATORIES, INC." on Justia Law
Posted in:
Class Action, Consumer Law
Estate of Bride v. Yolo Technologies, Inc.
The case involves the plaintiffs, including the estate of Carson Bride and three minors, who suffered severe harassment and bullying through the YOLO app, leading to emotional distress and, in Carson Bride's case, suicide. YOLO Technologies developed an anonymous messaging app that promised to unmask and ban users who engaged in bullying or harassment but allegedly failed to do so. The plaintiffs filed a class action lawsuit against YOLO, claiming violations of state tort and product liability laws.The United States District Court for the Central District of California dismissed the plaintiffs' complaint, holding that Section 230 of the Communications Decency Act (CDA) immunized YOLO from liability. The court found that the claims sought to hold YOLO responsible for third-party content posted on its app, which is protected under the CDA.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court's dismissal of the plaintiffs' misrepresentation claims, holding that these claims were based on YOLO's promise to unmask and ban abusive users, not on a failure to moderate content. The court found that the misrepresentation claims were analogous to a breach of promise, which is not protected by Section 230. However, the court affirmed the dismissal of the plaintiffs' product liability claims, holding that Section 230 precludes liability because these claims attempted to hold YOLO responsible as a publisher of third-party content. The court concluded that the product liability claims were essentially about the failure to moderate content, which is protected under the CDA. View "Estate of Bride v. Yolo Technologies, Inc." on Justia Law
CALHOUN V. GOOGLE LLC
A group of Google Chrome users who chose not to sync their browsers with their Google accounts alleged that Google collected their personal data without consent. They believed that, based on Google's Chrome Privacy Notice, their data would not be collected if they did not enable sync. The users filed a class action lawsuit against Google, claiming violations of various state and federal laws.The United States District Court for the Northern District of California granted summary judgment in favor of Google. The court found that the data collection was "browser-agnostic," meaning it occurred regardless of the browser used. It concluded that Google's general privacy policies, which the users had consented to, governed the data collection. The court held that a reasonable person would understand from these policies that Google collected data when users interacted with Google services or third-party sites using Google services.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision. The appellate court held that the district court should have determined whether a reasonable user would understand Google's various privacy disclosures as consenting to the data collection. The court found that the district court erred by focusing on the technical distinction of "browser agnosticism" rather than the reasonable person standard. The appellate court noted that Google's Chrome Privacy Notice could lead a reasonable user to believe that their data would not be collected without enabling sync. The case was remanded to the district court for further proceedings to determine whether the users consented to Google's data collection practices. View "CALHOUN V. GOOGLE LLC" on Justia Law
Posted in:
Class Action, Consumer Law
MELENDRES V. SKINNER
The case involves a class action lawsuit against the Maricopa County Sheriff’s Office (MCSO) for racially profiling Latino drivers and passengers under the guise of immigration enforcement. Plaintiffs sought declaratory and injunctive relief for violations of their Fourth and Fourteenth Amendment rights. The district court issued a permanent injunction in 2013, followed by a supplemental injunction appointing an independent monitor to oversee MCSO’s compliance. In 2016, a second supplemental injunction required MCSO to reform its internal misconduct investigation procedures. In 2022, a third supplemental injunction found the Sheriff in contempt for non-compliance and set forth curative measures, including creating a Constitutional Policing Authority (CPA) and assigning its duties to the Monitor.The United States District Court for the District of Arizona initially issued the permanent injunction and subsequent supplemental injunctions. The court found MCSO in contempt for failing to comply with the injunctions and ordered additional remedial measures. The district court relied on its inherent equitable powers rather than Federal Rule of Civil Procedure 53 in issuing these orders.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the district court’s amended third supplemental permanent injunction. It held that the district court acted within its inherent equitable powers in assigning the CPA’s duties to the Monitor. The court rejected the Sheriff’s contention that this assignment violated Article III of the Constitution and separation of powers principles. It also found that the First Order provided adequate judicial review of the Monitor’s actions and that the Third Order did not contravene Federal Rule of Civil Procedure 65’s specificity requirement. The Ninth Circuit concluded that the district court’s actions were appropriate and affirmed the Third Order. View "MELENDRES V. SKINNER" on Justia Law
JAMA V. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY
Plaintiffs, representing a class of drivers whose cars were totaled in accidents, alleged that their insurers, State Farm Mutual Automobile Insurance Company and State Farm Fire and Casualty Company, failed to pay the actual cash value of their vehicles. They contended that State Farm applied two unlawful discounts: a negotiation discount, which reduced the value based on typical buyer negotiations, and a condition discount, which adjusted for the car's condition compared to similar vehicles.The United States District Court for the Western District of Washington initially certified two classes: a negotiation class and a condition class. However, following the Ninth Circuit's decision in Lara v. First National Insurance Company of America, the district court decertified both classes and granted summary judgment in favor of State Farm, concluding that the plaintiffs failed to demonstrate injury.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court's decertification of the negotiation class, holding that plaintiffs could prove injury on a class-wide basis by adding back the unlawful negotiation adjustment to determine the value each class member should have received. However, the court affirmed the decertification of the condition class, as determining injury required an individualized comparison of the unlawful condition adjustment and a hypothetical lawful adjustment.The Ninth Circuit also vacated the district court's summary judgment against the named plaintiffs, remanding the case for the district court to reassess whether the plaintiffs provided sufficient evidence of injury. The court clarified that plaintiffs could rely on the Autosource reports, minus the unlawful adjustments, as relevant evidence of injury. The court rejected State Farm's argument that Article III standing was a barrier to the plaintiffs' suit, affirming that the plaintiffs' claim of receiving less than owed under their insurance policies constituted a concrete injury. View "JAMA V. STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY" on Justia Law
COX V. COINMARKETCAP OPCO, LLC
Ryan Cox filed a class action lawsuit alleging that the defendants manipulated the price of a cryptocurrency called HEX by artificially lowering its ranking on CoinMarketCap.com. The defendants include two domestic companies, a foreign company, and three individual officers of the foreign company. Cox claimed that the manipulation caused HEX to trade at lower prices, benefiting the defendants financially.The United States District Court for the District of Arizona dismissed the case for lack of personal jurisdiction, concluding that Cox needed to show the defendants had sufficient contacts with Arizona before invoking the Commodity Exchange Act's nationwide service of process provision. The court found that none of the defendants had sufficient contacts with Arizona.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the Commodity Exchange Act authorizes nationwide service of process independent of its venue requirement. The court concluded that the district court had personal jurisdiction over the U.S. defendants, CoinMarketCap and Binance.US, because they had sufficient contacts with the United States. The court also found that Cox's claims against these defendants were colorable under the Commodity Exchange Act. Therefore, the court reversed the district court's dismissal of the claims against the U.S. defendants and remanded for further proceedings.However, the Ninth Circuit affirmed the district court's dismissal of the claims against the foreign defendants, Binance Capital and its officers, due to their lack of sufficient contacts with the United States. The court vacated the dismissal "with prejudice" and remanded with instructions to dismiss the complaint against the foreign defendants without prejudice. View "COX V. COINMARKETCAP OPCO, LLC" on Justia Law
MAX ROYAL LLC V. ATIEVA, INC.
Plaintiff-investors brought a securities fraud class action against Atieva, Inc., d/b/a Lucid Motors, and its CEO, Peter Rawlinson. They alleged that Rawlinson made misrepresentations about Lucid's production capabilities, which affected the stock price of Churchill Capital Corp. IV (CCIV), a special purpose acquisition company (SPAC) in which the plaintiffs were shareholders. These misrepresentations were made before Lucid was acquired by CCIV. Plaintiffs purchased CCIV stock based on these statements but did not own any Lucid stock, as Lucid was privately held at the time.The United States District Court for the Northern District of California initially held that the plaintiffs had statutory standing but dismissed the action for failure to allege a material misrepresentation. The court allowed plaintiffs to amend their complaint, but ultimately denied the amendments as futile and dismissed the case with prejudice, concluding that the plaintiffs had not plausibly alleged materiality.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s dismissal on an alternative ground. The Ninth Circuit held that the plaintiffs lacked standing under Section 10(b) of the Exchange Act, following the Birnbaum Rule, which limits standing to purchasers or sellers of the stock in question. The court agreed with the Second Circuit's precedent in Menora Mivtachim Ins. Ltd. v. Frutarom Indus. Ltd., holding that purchasers of a security of an acquiring company (CCIV) do not have standing to sue the target company (Lucid) for alleged misstatements made prior to the merger. Consequently, the Ninth Circuit affirmed the dismissal of the suit on the ground that the plaintiffs lacked standing. View "MAX ROYAL LLC V. ATIEVA, INC." on Justia Law