Justia U.S. D.C. Circuit Court of Appeals Opinion Summaries

Linda Martin filed a class action lawsuit against the FBI, alleging that the Notice of Seizure provided to property owners did not meet the Due Process requirements under the Fifth Amendment. The FBI had seized $40,200 from Martin's safe deposit box and issued a Notice of Seizure, which Martin claimed lacked specific legal or factual bases for the seizure, thus denying her a meaningful opportunity to respond. Martin sought declaratory and injunctive relief for herself and a proposed nationwide class of individuals who had received similar notices.The United States District Court for the District of Columbia dismissed Martin's individual claim as moot after the FBI returned her seized property. The court also dismissed the class action for failure to exhaust administrative remedies and for failure to state a plausible Due Process claim. The court found that Martin had an adequate opportunity to present her Due Process challenge during the administrative proceedings and that her claim was moot because the FBI had returned her property.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court affirmed the district court's dismissal of Martin's individual claim as moot, as the FBI had returned her property. The court also dismissed the appeal of the class certification judgment for lack of jurisdiction, noting that Martin had not challenged the denial of class certification in her appellate briefs. The court concluded that without a certified class, it lacked jurisdiction to review the district court's merits rulings on the Due Process and exhaustion claims. View "Martin v. FBI" on Justia Law

Eight citizens of Mali alleged that, as children, they were trafficked to Côte d’Ivoire and forced to work without pay on small, remote cocoa farms. After eventually returning to Mali, they brought a putative class action in the United States against seven major cocoa importers, claiming the companies violated the Trafficking Victims Protection Reauthorization Act (TVPRA) by knowingly benefiting from a supply chain that relied on forced child labor. The plaintiffs asserted that the importers orchestrated and controlled a cocoa supply chain “venture” and delayed meaningful action against child labor through their leadership of the World Cocoa Foundation.The United States District Court for the District of Columbia dismissed the complaint for lack of standing. The court found that the plaintiffs failed to connect the defendants to any specific cocoa plantations, including those where the plaintiffs had worked. The court concluded that the plaintiffs’ general, industry-wide allegations lacked the specificity required to establish causation under Article III of the Constitution. The plaintiffs appealed, and the United States Court of Appeals for the District of Columbia Circuit held the appeal in abeyance pending resolution of a similar case, Doe 1 v. Apple Inc.The United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s dismissal. The appellate court held that the plaintiffs lacked Article III standing because they did not plausibly allege facts showing a causal connection between their forced labor and the importers’ conduct. Specifically, the complaint failed to allege that the importers sourced cocoa, directly or through intermediaries, from the specific farms where the plaintiffs worked. The court distinguished this case from Doe 1 v. Apple Inc., where plaintiffs had plausibly traced their injuries to the defendants’ suppliers. The dismissal was affirmed. View "Coubaly v. Cargill Incorporated" on Justia Law

Adam Steele and Krystal Comer, tax return preparers, challenged the IRS's requirement to obtain or renew a Preparer Tax Identification Number (PTIN) by completing Form W-12, which involves paying a fee and disclosing personal information. They initially joined a class action in 2014 contesting the IRS's authority to impose these fees and the amount of information required by Form W-12. However, class counsel later withdrew these claims. Steele and Comer then attempted to revive these claims in a separate lawsuit.The United States District Court for the District of Columbia dismissed their complaint, citing the rule against claim-splitting, which prevents duplicative litigation between the same parties asserting the same claims, even without a final judgment in the first case. The district court found that Steele and Comer had already raised and then withdrawn these claims in the ongoing class action and were denied leave to amend the complaint to reassert them.On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the district court's dismissal. The appellate court held that the Paperwork Reduction Act (PRA) does not bar judicial review of the IRS's authority to demand information through Form W-12, but the rule against claim-splitting still precludes the plaintiffs' suit. The court emphasized that claim-splitting bars duplicative litigation filed before final judgment and that Steele and Comer had a fair opportunity to litigate their claims in the earlier class action. The court concluded that the district court's dismissal was proper to prevent strategic end runs around procedural rulings and to preserve the integrity of the adjudicative process. View "Steele v. United States" 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

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

The appellants in this case were arrested by the Metropolitan Police Department (MPD) during protests in August 2020. Upon arrest, their personal property, including cell phones, was seized. They were released without charges, but their property was not returned for months or even over a year, despite repeated requests. The appellants filed motions under D.C. Rule of Criminal Procedure 41(g) to recover their property, which led to the return of some items after significant delays. They then sued the District of Columbia in federal court, alleging violations of the Fourth and Fifth Amendments and common-law conversion, and sought damages and injunctive relief.The United States District Court for the District of Columbia dismissed the complaints. It held that the plaintiffs failed to state a Fourth Amendment claim because the initial seizure was reasonable and any challenge to continued retention was governed by the Fifth Amendment. The court also found that Rule 41(g) provided adequate process for the Fifth Amendment claim. Consequently, it declined to exercise supplemental jurisdiction over the conversion claim and denied class certification as moot.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Fourth Amendment requires that any continued retention of personal property seized incident to a lawful arrest must be reasonable. The court found that the prolonged retention of the appellants' property without a legitimate investigatory or protective purpose could constitute an unreasonable seizure under the Fourth Amendment. The court reversed the dismissal of the Fourth Amendment claims, vacated the dismissal of the D.C.-law claims and the denial of class certification, and remanded the case for further proceedings. View "Oyoma Asinor v. DC" on Justia Law

Carol Lewis and Douglas Sargent, both diabetics and Medicare beneficiaries, sought reimbursement for continuous glucose monitors and related supplies from 2015 to 2017. After the Department of Health and Human Services (HHS) denied their claims, they pursued judicial review and sought to represent a class of individuals with similar claims. The district court denied their motion for class certification, noting that most putative class members had unexhausted or untimely claims. The court concluded that neither waiver of the exhaustion requirement nor equitable tolling of the limitations period was appropriate, reducing the putative class to seventeen individuals, which was too small to meet the numerosity requirement for class certification. After the Centers for Medicare & Medicaid Services (CMS) issued new guidance in 2022, the district court granted partial judgment in favor of Lewis and Sargent, setting aside the denials of their claims and declaring that continuous glucose monitors are durable medical equipment.Lewis and Sargent appealed the denial of class certification to the United States Court of Appeals for the District of Columbia Circuit. They did not challenge the favorable merits judgment but focused solely on the class certification issue. The Court of Appeals, however, dismissed their appeal for lack of constitutional standing. The court held that their desire to serve as class representatives did not create a cognizable Article III interest, as they did not allege any concrete individual injury resulting from the denial of class certification. The court emphasized that an abstract interest in representing a class is insufficient to satisfy the requirements of Article III standing. Consequently, the appeal was dismissed for lack of jurisdiction. View "Lewis v. Becerra" on Justia Law

Appellees worked as non-emergency medical transportation drivers. In July 2017, they brought a putative class action and Fair Labor Standards Act collective action against Medical Transportation Management, Inc. (“MTM”). Their complaint alleged that MTM is their employer and had failed to pay them and its other drivers their full wages as required by both federal and District of Columbia law. MTM appealed the district court’s certification of an “issue class” under Federal Rule of Civil Procedure 23(c)(4) and its denial of MTM’s motion to decertify plaintiffs’ Fair Labor Standards Act collective action.   The DC Circuit remanded the district court’s certification of the issue class because the court failed to ensure that it satisfies the class-action criteria specified in Rules 23(a) and (b). The court declined to exercise pendent appellate jurisdiction to review the district court’s separate decision on the Fair Labor Standards Act collective action. The court explained that because the resolution of the action will bind absent class members, basic principles of due process require that they be notified that their individual claims are being resolved and that they may opt out of the action if they so choose. So if the district court certifies the issue class under Rule 23(b)(3) on remand, it must direct “the best notice that is practicable” as part of any certification order. View "Isaac Harris v. Medical Transportation Management, Inc." on Justia Law

Plaintiffs sought class certification to pursue various claims against the Hilton Hotels Retirement Plan (“Hilton Plan”) for what they say are unlawfully denied vested retirement benefits. The district court ultimately denied certification on the ground that Plaintiffs had proposed an “impermissibly ‘fail-safe’” class—that is, a class definition for which membership can only be ascertained through “a determination of the merits of the case.”   The DC Circuit reversed and remanded the district court’s decision, finding that the district court, in this case, bypassed Rule 23’s requirements and based its denial of class certification entirely on the class’s “fail-safe” character. The court explained that the textual requirements of Rule 23 are fully capable of guarding against unwise uses of the class action mechanism. So the court rejected a rule against “fail-safe” classes as a freestanding bar to class certification ungrounded in Rule 23’s prescribed criteria. Instead, district courts should rely on the carefully calibrated requirements in Rule 23 to guide their class certification decisions and the authority the Rule gives them to deal with curable misarticulations of a proposed class definition. View "In re: Valerie White" on Justia Law

Plaintiffs in districts across the country filed class action complaints against four airlines, alleging violations of the Sherman Act, 15 U.S.C. 1, 3, by colluding to decrease capacity and raise prices. These lawsuits were consolidated and transferred to the District of Columbia for multidistrict litigation proceedings. The plaintiffs reached settlement agreements with Southwest and American. The district court preliminarily approved both settlements. Settlement class members include anyone who purchased flights from the defendant airlines for a period after July 2011. Litigation against Delta and United continued. Under the proposed settlements, Southwest would pay $15 million and American would pay $45 million. The amount ultimately received by each settlement class member may increase at the close of litigation against Delta and United. To avoid piecemeal payments, the proposed settlements left open the question of how the funds should be allocated and distributed until the entire lawsuit concluded.Bednarz and Frank objected, arguing the settlement notice should have detailed how the funds would be distributed and opposing the possibility of a cy pres distribution of funds to undisclosed recipients. After a hearing, the district court approved the settlements, rejecting the objections. The court dismissed Southwest and American from the consolidated action but declined to make the dismissal a final judgment. The D.C. Circuit dismissed, for lack of jurisdiction, an appeal by Bednarz and Frank. The court’s order is not an appealable final judgment or interlocutory order. View "In re: Domestic Airline Travel Antitrust Litigation" on Justia Law