Maston v. Bluestar Refreshment Services

Filing 55

ORDER regarding recent decision addressing standing for class settlement. Signed by Chief Magistrate Judge Joseph C. Spero on March 20, 2019. (jcslc2S, COURT STAFF) (Filed on 3/20/2019)

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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CHRISTOPHER MASTON,
Plaintiff,

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United States District Court
Northern District of California

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Case No. 17-cv-06000-JCS

v.
BLUESTAR REFRESHMENT SERVICES,

ORDER REGARDING RECENT
DECISION ADDRESSING STANDING
FOR CLASS SETTLEMENT

Defendant.

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At the hearing on Plaintiff Christopher Maston’s motion for preliminary approval of class

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settlement, the Court instructed the parties that any question of Maston’s Article III standing must

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be resolved before approval would be granted. To the extent that there might have been any doubt

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as to that requirement at the time of the hearing, the Supreme Court has now conclusively

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addressed the issue:

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“We have an obligation to assure ourselves of litigants’ standing
under Article III.” DaimlerChrysler Corp. v. Cuno, 547 U. S. 332,
340 (2006) (quoting Friends of the Earth, Inc. v. Laidlaw
Environmental Services (TOC), Inc., 528 U. S. 167, 180 (2000);
internal quotation marks omitted). That obligation extends to court
approval of proposed class action settlements. In ordinary non-class
litigation, parties are free to settle their disputes on their own terms,
and plaintiffs may voluntarily dismiss their claims without a court
order. Fed. Rule Civ. Proc. 41(a)(1)(A). By contrast, in a class action,
the “claims, issues, or defenses of a certified class—or a class
proposed to be certified for purposes of settlement—may be settled,
voluntarily dismissed, or compromised only with the court’s
approval.” Fed. Rule Civ. Proc. 23(e). A court is powerless to approve
a proposed class settlement if it lacks jurisdiction over the dispute,
and federal courts lack jurisdiction if no named plaintiff has standing.
Simon v. Eastern Ky. Welfare Rights Organization, 426 U. S. 26, 40,
n. 20 (1976).

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Frank v. Gaos, 586 U.S. __, No. 17-961 (Mar. 20, 2019) (per curiam) (remanding for the lower

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courts to address unresolved issues of the named plaintiffs’ Article III standing in light of Spokeo,

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Inc. v. Robins, 136 S. Ct. 1540 (2016)).

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The parties are therefore reminded that any supplemental submissions in support of

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Maston’s motion for preliminary approval must show that Maston has Article III standing to bring

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his claims. Moreover, if the parties are able to show affirmatively that Maston has standing, the

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parties must address whether the previously-proposed settlement value—which, according to the

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motion, reflected a significant discount to account for the unresolved issue of standing—remains a

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“fair, reasonable, and adequate” settlement of the claims. See Fed. R. Civ. P. 23(e)(2).

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This order, issued in light of the recent decision by the Supreme Court and focused

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narrowly on the standing issue addressed therein, is not intended as a complete restatement of all

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issues identified at the previous hearing for the parties to address.

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United States District Court
Northern District of California

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IT IS SO ORDERED.
Dated: March 20, 2019
______________________________________
JOSEPH C. SPERO
Chief Magistrate Judge

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