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

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

Plaintiffs filed suit against CareFirst after hackers allegedly stole sensitive customer information from the health insurer's data system, alleging tort, contract, and statutory claims. The district court dismissed all claims of five plaintiffs and most claims of two plaintiffs. At issue was whether the district court permissibly certified the dismissed claims under Federal Rule of Civil Procedure 54(b), so as to make the dismissal order final and immediately appealable.The DC Circuit held that it lacked appellate jurisdiction over the certified claims of the Tringlers and of the other plaintiffs. Under basic principles of claim preclusion, the court explained that the Tringlers could not have litigated to judgment one action involving the claims still pending before the district court and another involving the claims already dismissed. Under Tolson v. United States, 732 F.2d 998, 1001–03 (D.C. Cir. 1984), they likewise cannot sever the latter claims for an immediate appeal under Rule 54(b). In regard to the non-Tringler claims, the court stated that it is unclear whether the district court would have certified these claims for immediate appeal had it properly declined to certify the claims of the Tringlers. Therefore, the court cannot determine whether the district court would have certified only the non-Tringler claims, much less whether it could have come up with a permissible justification for doing so. View "Attias v. CareFirst, Inc." on Justia Law

Current and former Whole Foods employees initiated this diversity action seeking to recover purportedly lost wages, alleging that Whole Foods manipulated its incentive-based bonus program, resulting in employees losing wages otherwise owed to them. In the not yet certified class action, Whole Foods moved to dismiss all nonresident putative class members for lack of personal jurisdiction.The DC Circuit affirmed the district court's denial of Whole Foods' motion to dismiss, on alternative grounds, holding that putative class members -- absent class certification -- are not parties before a court and thus Whole Foods' motion was premature. The court wrote that, only after the putative class members are added to the action, should the district court entertain Whole Foods' motion to dismiss the non-named class members. Finally, the court held that Whole Foods' remaining arguments were without merit. View "Molock v. Whole Foods Market Group, Inc." on Justia Law

The DC Circuit affirmed the district court's denial of class certification in a putative class action of over 16,000 shippers allegedly harmed by a price-fixing conspiracy among the nation's largest freight railroads. The court held that the district court did not abuse its discretion by determining that plaintiffs' regression analysis—their evidence for proving causation, injury, and damages on a class-wide basis—measured negative damages for over 2,000 members of the proposed class. Therefore, common issues did not predominate where at least 2,037 individual determinations of injury and causation were needed. Furthermore, the district court did not abuse its discretion by holding that this analysis was essential to plaintiffs' case for certification. View "In re: Rail Freight Fuel Surcharge Antitrust Litigation" on Justia Law

While district courts generally have discretion under Federal Rule of Civil Procedure 60(b)(5) to adjust the terms of an existing consent decree in light of changed circumstances, the issuance of a new injunction must meet the strict preconditions for such exceptional relief set out in Federal Rule of Civil Procedure 65. This case stemmed from a putative class action brought by a broad group of Medicaid applicants and recipients against the District. The parties eventually reached a settlement and a consent decree was issued. Plaintiffs subsequently filed a motion for a preliminary injunction and renewals under the Affordable Care Act. About a week after briefing on the preliminary injunction concluded, plaintiffs filed a motion under Federal Rules of Civil Procedure 60(b)(5) and (b)(6) to "modify" the Consent Decree to achieve precisely the same relief as the pending motion for a preliminary injunction. The district court granted the motion to modify and denied the motion for a preliminary injunction as moot.The DC Circuit held that the district court's order provided brand new relief based on brand new facts alleging violations of a new law without the requisite findings for an injunction, and thus it crossed the line from permissibly modifying into impermissibly enjoining. Accordingly, the court reversed the district court's judgment, vacated the new injunctive relief, and remanded for further proceedings. View "Salazar v. District of Columbia" on Justia Law

The DC Circuit affirmed the district court's denial of plaintiffs' motion to compel payment of attorneys' fees that they say should have been but were not paid as a result of PBGC doing too little to identify and make payments to class members. The court's de novo interpretation of the wrap-up agreement gave it no reason to question the district court's conclusion that PBGC fully performed notwithstanding class counsel's unsupported assertions to the contrary. The court also held that PBGC did not prevent class counsel's performance of the wrap-up agreement. In this case, the parties intended that the wrap-up would be complete within ten years. This ten year period was unambiguous and has expired. View "Collins v. PBGC" on Justia Law