James Bogan III

James Bogan III

Kilpatrick Townsend & Stockton LLP

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Sixth Circuit solidifies circuit split by rejecting “juridical link” exception to class action standing

Takeaway: Federal Rule 23 authorizes representative litigation in the form of class actions that satisfy its various requirements. The policy underlying the rule is efficiency. For example, the numerosity element (Rule...more

6/6/2023  /  Class Action , Class Certification , Class Members , FRCP 23

Eleventh Circuit strikes again, vacating class settlement for lack of standing

Takeaway: We have written about Eleventh Circuit decisions on Article III standing and its relationship to the proper approval of a class action settlement. See Eleventh Circuit holds that every class member must have...more

5/31/2023  /  Article III , Class Action , Class Action Settlement , Class Members , Standing

RICO class actions: D. Conn. rules that legal entity must have or share a common fraudulent purpose to qualify as a RICO...

Takeaway: There are, essentially, two ways to defeat a RICO class action: through the denial of class certification or by the dismissal of the RICO claims on the merits. We have written a number of articles about both the...more

5/30/2023  /  Class Action , Class Certification , Fraud , RICO

Eleventh Circuit Grants en banc Review to Resolve Controversial TCPA Standing Ruling [Video]

Atlanta Partner Jay Bogan recently covered the Eleventh Circuit in his new Class Action blog post discussing the TCPA Standing Ruling....more

3/27/2023  /  Class Action , Standing , TCPA

Eleventh Circuit grants en banc review to resolve controversial TCPA standing ruling

We have written about the Eleventh Circuit’s controversial ruling in Salcedo v. Hanna, 936 F.3d 1162 (11th Cir. 2019). See Eleventh Circuit reinvigorates Spokeo in single text message TCPA case (Sep. 11, 2019). In Salcedo,...more

3/24/2023  /  Article III , Class Action , Standing , TCPA , Telecommunications , Text Messages

Fifth Circuit Affirms District Court’s Striking of Class Allegations [Video]

Partner Jay Bogan discusses the Fifth Circuit affirming of district court’s striking of class allegations and dismissal of inadequately alleged fraud-based claims....more

2/6/2023  /  Class Action , Dismissals , Fraud

Fifth Circuit affirms district court’s striking of class allegations and dismissal of inadequately alleged fraud-based claims

Takeaway:  We have written several articles about motions to strike class action allegations. See, e.g., Motions to strike: Eighth Circuit reverses district court refusal to strike class allegations (July 29, 2021).  In a...more

2/1/2023  /  Class Action , Fraud , Motion To Strike , Putative Class Actions

Ninth Circuit rules that excessive, aggregated awards of statutory damages are subject to review on constitutional due-process...

Takeaway: Statutes that impose per-violation statutory damages, like the Telephone Consumer Protection Act (TCPA), can lead to astronomical class action verdicts. In Wakefield v. ViSalus, Inc., 51 F.4th 1109 (2022), a Ninth...more

12/21/2022  /  Damages , Due Process , Statutory Damages , TCPA

SCOTUS grants cert. to determine whether an appeal of an order denying a motion to compel arbitration automatically stays district...

Takeaway: To control litigation risk, a business might include an arbitration clause and class action waiver in its consumer-facing terms and conditions. When a consumer files a putative class action against that business,...more

12/21/2022  /  Arbitration , Certiorari , Motion to Compel , Putative Class Actions , SCOTUS

Data breach class actions: Ninth Circuit addresses forum selection and personal jurisdictional issues in case against foreign...

Takeaway:  Businesses oftentimes rely on contractual provisions to shield themselves from litigation risk.  But some provisions are more effective than others.  In Baton v. Ledger SAS, No. 21-17036, 2022 WL 17352192 (9th Cir....more

12/21/2022  /  Class Action , Cybersecurity , Data Breach , Data Privacy , Data Protection , Data Security , Popular

Fifth Circuit: civil RICO class action against Southwest Airlines and Boeing cannot stand for lack of Article III injury-in-fact

Takeaway: Over two years ago, the Eastern District of Texas denied a motion to dismiss a putative civil RICO class action alleging an “overcharge-by-fraud” theory, where the class representatives appeared to have suffered no...more

11/30/2022  /  Article III , Boeing , Class Action , Corporate Counsel , Fraud , RICO , Southwest Airlines , Standing

Data breach class actions: SDNY finds standing based on sketchy injury-in-fact allegations

Takeaway: Ever since the U.S. Supreme Court ruled in Clapper v. Amnesty Int’l USA, 568 U.S. 398, 416 (2013), that plaintiffs “cannot manufacture standing merely by inflicting harm on themselves based on . . . hypothetical...more

11/30/2022  /  Article III , Class Action , Corporate Counsel , Cybersecurity , Data Breach , Data Protection , Data Security , Injury-in-Fact , Personal Information , Popular , Standing

Middle District of Georgia dismisses putative class action against State Farm for failure to comply with “appraisal” condition...

We have written about class actions filed against State Farm and other carriers alleging systematic undervaluation of damaged vehicles. See, e.g., Eleventh Circuit emphasizes the abuse of discretion standard in affirming the...more

11/17/2022  /  Auto Insurance , Class Action , Insurance Industry , Putative Class Actions , State Farm

Data breach class actions: District of Massachusetts dismisses complaint for failure to allege injury-in-fact

Takeaway:  We have written a number of articles about standing issues arising in data breach class actions.  See, e.g., Data breach class actions: Third Circuit sets out parameters for Article III injury-in-fact (Oct. 27,...more

10/28/2022  /  Article III , Class Action , Cybersecurity , Data Breach , Data Protection , Hackers , Injury-in-Fact , Personally Identifiable Information , Putative Class Actions , Standing

Data breach class actions: Third Circuit sets out parameters for Article III injury-in-fact

Takeaway:  We have written a number of articles about the kinds of intangible injuries that confer Article III standing in the data breach and credit reporting contexts.  See Data breach class actions: Southern District of...more

10/27/2022  /  Article III , Class Action , Cybersecurity , Data Breach , Hackers , Injury-in-Fact , Personal Information , Popular , Standing

Wiretap class actions: Third Circuit reinstates class claims asserted under Pennsylvania’s broad wiretap act

Takeaway:  State wiretap acts have been around for a long time, and they can provide greater protection to victims of intercepted communications than the Federal Wiretap Act, 18 U.S.C. § 2510.  These statutes generally...more

10/3/2022  /  Class Action , Electronic Communications , Wiretap Act , Wiretapping

Class Action | Eleventh Circuit Reinstates No Hire Antitrust Claims Against Burger King [Video]

Partner Jay Bogan recently discussed the Eleventh Circuit Reinstating No Hire Antitrust Claims Against Burger King....more

10/3/2022  /  Antitrust Violations , Employer Liability Issues , Franchise Agreements , Hiring & Firing , No-Hire/No-Solicitation Agreements , No-Poaching , Putative Class Actions , Restrictive Covenants , Sherman Act

Sixth Circuit grants Rule 23(f) interlocutory review in one of the largest class actions ever

Takeaway:  In the U.S. Supreme Court’s seminal decision in Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338, 342 (2011), the court described a class consisting of 1.5 million class members as “one of the most expansive” classes...more

9/29/2022  /  Class Action , Class Certification , Dukes v Wal-Mart , FRCP 23(f) , Interlocutory Appeals , PFAS

Eleventh Circuit reinstates no-hire antitrust claims against Burger King

Takeaway: Restrictive covenants have generated a lot of controversy lately, especially with the Department of Justice’s continued focus on illegal no-poach hiring agreements between Silicon Valley companies and other firms. ...more

9/19/2022  /  Antitrust Violations , Burger King , Class Action , Franchise Agreements , No-Hire/No-Solicitation Agreements , Sherman Act

Eleventh Circuit emphasizes the abuse of discretion standard in affirming the denial of certification of a “diminution in value”...

Takeaway: From the perspective of attorneys representing class action defendants, it seems that some circuits (especially the Ninth Circuit) do not give much deference to district court decisions denying class certification....more

9/2/2022  /  Class Action , Class Certification , Class Members , FRCP 23(b)(3) , Predominance Requirement

Seven Key Takeaways: Class Certification in the Ninth Circuit – Predominance

Kilpatrick Townsend partner Jay Bogan, along with three other panel members, recently presented “Class Certification after Olean v. Bumble Bee: Expert Testimony, Uninjured Class Members, and Article III Standing.” This...more

9/1/2022  /  Admissible Evidence , Article III , Class Action , Class Certification , Expert Testimony , FRCP 23(b)(3) , Predominance Requirement , Standard of Proof , Standing

Eleventh Circuit holds that every class member must have standing for a class action settlement to be approved

Takeaway: We have posted articles addressing the U.S. Supreme Court’s standing-related decision in Frank v. Gaos, 139 S. Ct. 1041 (2019), as well as its decision in TransUnion, LLC v. Ramirez, 141 S. Ct. 2190 (2021). In a...more

8/23/2022  /  Article III , Class Action , Class Members , Injury-in-Fact , Standing , TransUnion LLC v Ramirez

Fifth Circuit refuses to address non-CAFA grounds for remand where defendant petitioned to appeal remand decision under CAFA (28...

Takeaway: The Class Action Fairness Act (CAFA) provides class action defendants with the means to secure federal jurisdiction over putative class actions filed in state court, as well as a mechanism to appeal decisions by...more

6/29/2022  /  CAFA , Class Action , Federal Jurisdiction , Jurisdiction , Putative Class Actions

SCOTUS displays short memory in rejecting the prejudice requirement for waivers of the right to arbitrate

Takeaway: In Morgan v. Sundance, Inc., --- S. Ct. ----, No. 21-328, 2022 WL 1611788 (May 23, 2022), the Supreme Court rejected the arbitration-specific rule requiring a finding of prejudice for a waiver of the right to...more

6/1/2022  /  Arbitration , Arbitration Agreements , Employment Litigation , Federal Arbitration Act , Morgan v Sundance , Motion to Compel , SCOTUS , Waivers

Data breach class actions: Southern District of New York dismisses action against health care providers for lack of standing

Takeaway: In a prior article, we reported on the Second Circuit’s decision in McMorris v. Carlos Lopez & Associates, LLC, 995 F.3d 295 (2d Cir. 2021), in which the court, ruling on an issue of first impression, set out a...more

5/26/2022  /  Article III , Class Action , Corporate Counsel , Cybersecurity , Data Breach , Hackers , Injury-in-Fact , Popular , Standing
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