Justia West Virginia Supreme Court of Appeals Opinion Summaries

The Supreme Court vacated the order of the circuit court denying two hospitals' motion to decertify the class after the court initially certified a class action against the hospitals, holding that the circuit court exceeded its jurisdiction by failing to conduct a sufficiently thorough analysis of whether the commonality required for class certification under W. Va. R. Civ. P. 23 was present.Respondent Phillip Gaujot, a judge of the circuit court, certified the class action against West Virginia University Hospitals, Inc. and West Virginia United Health System, Inc. The hospitals moved to decertify the class, but the Judge Gaujot denied the motion. The hospitals then filed a petition for a writ of prohibition asking the Supreme Court to prohibit Judge Gaujot from conducting any further proceedings until he vacated his order denying their motion to decertify the class. The Supreme Court granted the writ of prohibition as moulded, holding that the circuit court exceeded its legitimate powers by certifying the class while failing to conduct a sufficiently thorough analysis of the case to determine whether the commonality required for class certification under Rule 23 was present. View "State ex rel. West Virginia University Hospitals, Inc. v. Honorable Phillip D. Gaujot" on Justia Law

In this ancillary statutory proceeding in aid of collection on a judgment, the Supreme Court affirmed the ruling of the circuit court awarding summary judgment in favor of Respondents. Respondents were previously awarded a judgment against Employer in a class action alleging violations of the West Virginia Wage Payment and Collection Act. Respondents later caused a suggestion a personal property to be served upon Petitioner in which they sought amounts, obligations, and things of value owed to Employer. Respondents then sought to make Petitioner liable for Respondents’ judgment. The circuit court granted, in part, the motion to make Petitioner liable for Respondents’ judgment and then directed Petitioner to pay Respondents the amount of their judgment against Employer. The Supreme Court affirmed, holding that summary judgment was proper where Petitioner’s contractual obligations to Employer were subject to Respondents’ suggestion and where West Virginia law provides for suggestion upon unmatured debts. View "IPacesetters, LLC v. Douglas" on Justia Law

Respondent filed a putative class action alleging that Petitioner had failed to pay him and other similarly situated employees their final wages within the time period mandated by the West Virginia Wage Payment and Collection Act. Respondent served requests upon Petitioners seeking class discovery. Petitioner filed a motion to stay class discovery, arguing that the class discovery was overly broad, unduly burdensome, and premature. The circuit court denied the request to stay class discovery, finding that Petitioner had waived its objections to class discovery, as they were untimely raised, and had further failed to meet its burden of demonstrating why such discovery should not proceed. Petitioner appealed the circuit court’s interlocutory order and invited the Supreme Court to extend the collateral order doctrine to interlocutory discovery orders that implicate case management. The Court, however, chose to consider this matter as a petition for a writ of prohibition, granted the writ, and vacated the order denying Petitioner’s motion to stay class discovery, holding that the circuit court abused its discretion in refusing to stay class discovery pending a ruling on the threshold legal issue of statutory construction that bears on the viability of Respondent’s individual claim. Remanded. View "GMS Mine Repair & Maintenance, Inc. v. Milkos" on Justia Law

Plaintiffs, on behalf of themselves and others similarly situated, were former students in the nursing program at Salem International University (Salem). When Plaintiffs enrolled, they signed enrollment agreements that contained an arbitration clause. Plaintiffs filed a putative class action complaint against Salem and its president (collectively, Salem) alleging that they were denied the opportunity to complete their coursework in nursing at Salem as a result of the nursing program’s loss of accreditation. Salem filed a motion to stay proceedings pending mandatory alternative dispute resolution. The circuit court denied the motion, concluding that the arbitration agreement did not include an enforceable class action litigation waiver. The Supreme Court reversed, holding that the arbitration agreement acted as a class action litigation waiver barring Plaintiffs from seeking judicial relief as a class. View "Salem International University v. Bates" on Justia Law

Petitioners in these combined cases were former public employees who filed actions in the circuit court alleging violations of the West Virginia Human Rights Act (WVHRA). The circuit courts dismissed the complaints for Petitioners' failures to exhaust their administrative remedies, concluding that the exhaustion of administrative remedies available pursuant to the West Virginia Public Employees Grievance Procedure was a necessary precondition to the filing of a circuit court action. The Supreme Court reversed the rulings of the circuit courts, holding (1) a public employee, whose employment confers grievance rights before the West Virginia Public Employees Grievance Board, is not required to exhaust the administrative Grievance Procedure before initiating a complaint in the circuit court alleging violations of the WVHRA; and (2) the commencement of the Grievance Procedure does not preclude the institution of a circuit court action prior to exhaustion of the Grievance Procedure. Remanded.View "Weimer v. Sanders" on Justia Law

Plaintiffs filed an action individually and on behalf of a class of persons similarly situated against Respondents, Charleston Area Medical Center (CAMC) and CAMC Health Education and Research Institute, asserting causes of action for breach of duty of confidentiality, invasion of privacy, and negligence for placing Plaintiffs’ personal and medical information on a specific CAMC electronic database and website that was accessible to the public. The circuit court denied class certification, finding that Plaintiffs did not meet the prerequisites for class certification and that Plaintiffs lacked standing to sue Respondents. The Supreme Court reversed, holding that the circuit court erred in finding that Petitioners lacked standing and abused its discretion in ruling that Petitioners failed to meet the requirements for class certification. Remanded. View "Tabata v. Charleston Area Med. Ctr." on Justia Law

This case involved the appeal of Petitioner of her sentence of life without mercy imposed in the circuit court by order, as recommended by the jury which found Petitioner guilty of first degree murder. Petitioner assigned four errors committed by the trial court, including the admission of the decedent's statements, failure to give a Harden instruction, failure to give a good character instruction, and the failure to suppress one of Petitioner's statements to the police. The Supreme Court reversed the judgment of the circuit court and remanded the case for a new trial, holding (1) the court did not err in admitting the statements of the decedent; (2) the court's decision to admit the statement was not an abuse of discretion; but (3) under the limited circumstances of this case, the court erred in failing to give a proper good character instruction. View "State v. Surbaugh" on Justia Law

Plaintiffs William and Connie Huston sought to enforce the terms of a global class action settlement agreement in the circuit court when defendants Mercedes-Benz and Smith Motor Cars allegedly refused to repair the plaintiffs' sports utility vehicle in accordance with the settlement agreement. The defendants moved to dismiss, claiming that the circuit court did not have jurisdiction to adjudicate the Hustons' claims. The circuit court certified to the Supreme Court the question of the circuit court's authority to adjudicate the plaintiffs' lawsuit against the defendants. The Supreme Court concluded that the circuit court did not have jurisdiction to consider the plaintiffs' lawsuit because continuing jurisdiction over the settlement agreement had been retained by the federal district court where the global class action settlement agreement was originally reached. As such, the plaintiffs could not properly maintain their suit against the defendants in the circuit court. View "Huston, et al. v. Mercedes-Benz USA, L.L.C., et al." on Justia Law