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July 19th, 2016

Federal Courts in Two Top Hellholes Issue Refreshingly Reasonable Class-Action Decisions

Federal courts in both California and New York — two perennial Judicial Hellholes — issued refreshingly reasonable decisions in two closely-watched cases last week.

Magistrate Judge Stanley Boone

On July 15, California federal Magistrate Judge Stanely Boone slashed the plaintiffs’ lawyers’ $7.3 million fee request in a Taco Bell wage-and-hour class action to $1.15 million – roughly 16 percent of the original request. In doing so, Judge Boone called the fees “unreasonable” and “inflated.”  Several of class’s claims did not survive summary judgment, with Judge Boone finding in favor of Taco Bell.

Judge John Koetl

On the same day, the U.S. Court of Appeals for the Second Circuit decided that a class action may be decertified after a jury returns a verdict but before the court enters a final judgment.  In Mazzei v. Money Store, Southern District of New York Judge John Koetl decertified a class after the jury returned an award of more than $32 million. Judge Koetl recognized that the previously certified class’s claims suffered a lack of “typicality.”  The class’s claim required “privity,” which rested on too many facts dependent on individual class members’ circumstances.  The Second Circuit upheld Judge Koetl on appeal.

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