News & Analysis as of

Split of Authority Dismissals

Venable LLP

Supreme Court Forgoes Chance to Resolve Issue of Class Certification under Rule 23

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On June 5, 2025, the U.S. Supreme Court was set to rule in Labcorp v. Davis, which sought to resolve division among federal circuit courts regarding the certification of a damages class under Rule 23 of the Federal Rules of...more

Benesch

“Stay Awhile”: Supreme Court Tells District Courts Not to Dismiss Claims Pending Arbitration

Benesch on

In Smith v. Spizzirri, the Supreme Court unanimously held that federal district courts lack the power to dismiss a case sent to arbitration. Instead, under the Federal Arbitration Act, if a party moves to compel arbitration...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Divided Second Circuit Decides Long-Awaited Braille Gift Card Appeals, Affirming Dismissals Based on Standing

More than a year after oral arguments in Calcano v. Swarovski North America Ltd., No. 20-1552, the U.S. Court of Appeals for the Second Circuit affirmed a lower court’s dismissal of five nearly identical lawsuits brought by...more

Sheppard Mullin Richter & Hampton LLP

Split of Authority Emerges Regarding Whether Employers Can Dismiss PAGA Lawsuits on Manageability Grounds

On March 23, 2022, the California Court of Appeal for the Fourth District in Estrada v. Royalty Carpet Mills, Inc., ruled that courts do not have authority to strike a claim under the Private Attorneys General Act (“PAGA”)...more

Fisher Phillips

Federal Appeals Courts Add to Employers’ Confusion by Disagreeing on Whether to Dismiss Out-of-State Plaintiffs in FLSA Collective...

Fisher Phillips on

Over the past several years, many federal courts have weighed in on whether a key Supreme Court decision requires them to dismiss non-resident opt-in plaintiffs in federal wage and hour collective actions, and there is now...more

Dorsey & Whitney LLP

SCOTUS Denies Review of Dismissal at DOJ’s Request; Circuit Split Remains

Dorsey & Whitney LLP on

On June 28, 2021, the United States Supreme Court denied review of a Seventh Circuit decision affirming the Department of Justice (“DOJ”)-requested dismissal of a False Claims Act (“FCA”) suit alleging a drug kickback scheme....more

Latham & Watkins LLP

Seventh Circuit Deepens Circuit Split Over FCA Dismissal Authority

Latham & Watkins LLP on

The Seventh Circuit has created a third standard for evaluating motions to dismiss pursuant to the government’s FCA dismissal authority. The US Court of Appeals for the Seventh Circuit’s August 17, 2020, opinion in United...more

Hinshaw & Culbertson - Consumer Financial...

Consumer Law Hinsights – April 2020

Welcome to Consumer Law Hinsights?a monthly compilation of nationwide consumer protection cases of interest to financial services and accounts receivable management companies. This edition highlights our interactive COVID-19...more

Mintz - Employment Viewpoints

Supreme Court Clarifies Race Discrimination Claims Under 42 U.S.C. § 1981 Must Meet More Stringent “But-For” Causation Standard

Bringing positive news for employers and a welcome distraction from the COVID-19 crisis, the United States Supreme Court recently held that for claims of racial discrimination under Section 1981 of the Civil Rights Act of...more

Shook, Hardy & Bacon L.L.P.

National Employment Perspective | Focus on Discrimination

Supreme Court Issues Unanimous Opinion Upholding But-For Causation in Section 1981 Discrimination Cases - The U.S. Supreme Court has issued a unanimous opinion holding that a plaintiff who sues for racial discrimination in...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Supreme Court Requires But-For Causation for Section 1981 Claims

On March 23, 2020, the Supreme Court of the United States, in Comcast Corp. v. National Association of African-American Owned Media, ruled that a plaintiff who alleges race discrimination under 42 U.S.C. § 1981 must plead and...more

Fisher Phillips

SCOTUS Sets High Bar For Those Bringing Race Discrimination Cases

Fisher Phillips on

In a unanimous decision, the U.S. Supreme Court last week ensured that a high standard will be used when assessing whether claims of race discrimination under Section 1981 should advance past the early stages of litigation....more

McAfee & Taft

U.S. Supreme Court confirms ‘but for’ causation in Section 1981 cases

McAfee & Taft on

Surrounded by the confusion and anxiety of the current COVID-19 pandemic, it may feel refreshing to step back and consider some of the basic tenets of employment law. The U.S. Supreme Court’s recent decision in Comcast Corp....more

Hinshaw & Culbertson - Employment Law...

U.S. Supreme Court Holds Section 1981 Racial Discrimination Claims Require But-For Causation

In a unanimous decision issued on March 23, 2020, the United States Supreme Court held that a but-for causation standard applies to claims brought under Section 1981 of the Civil Rights Act of 1866. The Supreme Court also...more

Herbert Smith Freehills Kramer

Supreme Court Confirms Strict “But for” Causation Test Applies to Section 1981 Claims

On Monday, March 23, the United States Supreme Court, in a nearly unanimous opinion, ruled that a plaintiff asserting race discrimination claims in the making of a contract under 42 U.S.C. § 1981 (Section 1981) bears the...more

Franczek P.C.

Supreme Court Holds that Claims for Intentional Discrimination Under Section 1981 Must Meet “But For” Causation Test

Franczek P.C. on

Section 1981 of the Civil Rights Act prohibits intentional race discrimination in all forms of contracting including employment. Lower courts have split as to whether a § 1981 plaintiff must prove that race was only one...more

Foley Hoag LLP - White Collar Law &...

White Collar Year in Preview: False Claims Act Trends in 2020

Editors’ Note: This is the fourth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed anti-corruption trends in 2020. Up next: a look...more

Hudson Cook, LLP

After Oral Argument, High Court Seems Poised to Preserve FDCPA Status Quo

Hudson Cook, LLP on

In Rotkiske v. Klemm, the Supreme Court has the opportunity to do what many plaintiffs’ attorneys have dreamed of for years:  effectively expand the FDCPA’s one-year statute of limitations by applying the “discovery rule” to...more

Dorsey & Whitney LLP

Granston Memo in Action: Eighth Circuit Affirms Government Dismissal of FCA Claims Related to Minnesota Bridge Collapse

Dorsey & Whitney LLP on

Just days after the twelfth anniversary of the Minnesota 35W bridge collapse, the Eighth Circuit summarily affirmed the dismissal of a False Claims Act case alleging that Minnesota government officials conspired to submit...more

Skadden, Arps, Slate, Meagher & Flom LLP

Second Circuit Allows Avoidance Actions Against Foreign Transferees in Madoff Proceeding

On February 25, 2019, the U.S. Court of Appeals for the Second Circuit vacated the bankruptcy court’s dismissal of avoidance actions brought by Irving Picard, the trustee (Trustee) for the liquidation of Bernard L. Madoff...more

Cozen O'Connor

Quite The Split: Louisiana Third Circuit Court of Appeal Applies Ten-Year Prescriptive Period to Contract-Based Bad Faith Claims

Cozen O'Connor on

In a surprising decision on rehearing, on February 4, 2019, a panel of the Louisiana Third Circuit Court of Appeal reversed itself and held that bad faith claims arising out an insurance contract are subject to a ten-year...more

Mintz - Health Care Viewpoints

Amended FCA Complaint Cannot Cure A First-to-File Violation

The Second Circuit Court of Appeals recently held that a False Claims Act (FCA) relator could not evade the FCA’s first-to-file bar by filing an amended complaint after two earlier-filed FCA suits alleging similar conduct had...more

Proskauer - Law and the Workplace

[Podcast]: Recent Developments in Title VII

In this episode of The Proskauer Brief, senior counsel Harris Mufson and associate Laura Fant discuss the latest developments in Title VII. We will discuss the two recent circuit court decisions concerning the scope of sex...more

Proskauer - Law and the Workplace

Second Circuit Rules Sexual Orientation Discrimination Is Prohibited Under Title VII

In an en banc decision in Zarda v. Altitude Express, Inc., the Second Circuit has become the latest federal appeals court to hold that discrimination on the basis of sexual orientation is prohibited sex discrimination under...more

Akin Gump Strauss Hauer & Feld LLP

False Claims Act Circuit Splits—FCA Issues That May Soon Reach The Supreme Court Or Lead To Congressional Amendment

• Under the FCA there are multiple circuit court splits related to how power should be allocated between the United States and the relator and whether the relator has contributed sufficient value to merit obtaining a...more

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