Braswell v. Bow Plumbing Group, Inc.

District Court, M.D. Alabama·Decided May 23, 2024·No. 2:21-cv-00025·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION

ROSELYN BRASWELL, et al., ) ) Plaintiffs, ) ) v. ) CIVIL ACTION NO. 2:21-cv-25-ECM ) [WO] BOW PLUMBING GROUP, INC., ) ) Defendant. )

MEMORANDUM OPINION and ORDER

I. INTRODUCTION Now pending before the Court is the Plaintiffs’ Emergency Motion for Curative Action (doc. 109), filed on May 16, 2024. The Court carefully considered the motion and the materials in support (docs. 109-1 & 109-2), and it held a telephonic status conference on May 21, 2024, with all parties present. For the reasons stated at the status conference, and those that follow, the motion (doc. 109) is due to be GRANTED to the extent that: (1) the Court strikes the 319 requests for exclusion (or “opt-outs”) submitted by individuals or entities represented by Attorney Joseph “Jay” Aughtman; Aughtman Law Firm, LLC; Attorney Kenneth Mendelsohn; and/or Jemison & Mendelsohn, P.C. (those individuals or entities collectively, the “affected class members”); (2) the Court re-opens the opt-out and objection period for only those affected class members; and (3) the Court authorizes issuance of a second curative notice and request for exclusion form to the affected class members. The Court finds that these curative measures are necessary to ensure that the affected class members are adequately and fairly informed of the settlement terms before they decide to remain in the class settlement or opt out.

Additionally, the Court in its discretion finds that the final approval hearing currently set for July 9, 2024, is due to be continued to ensure that there is sufficient time to receive and process any requests for exclusion submitted during the renewed opt-out period and to resolve any potential issues regarding those requests for exclusion. II. BACKGROUND This case concerns alleged defects in Bow’s PEX tubing, which was installed in the

Plaintiffs’ and class members’ homes. On February 28, 2024, the Court preliminarily approved the parties’ proposed class action settlement, provisionally certified the settlement class, and directed notice to the settlement class. (Doc. 99). Days later, in early March 2024, Attorneys Jay Aughtman and Kenneth Mendelsohn—who represent plaintiffs in related state and federal court litigation against Bow, concerning the same alleged defects

in Bow’s PEX tubing—sent emails to a “blind-copied” or “bcc’ed” list of their clients, who presumptively are members of the settlement class unless they opt out. (See docs. 101-1 & 101-2). This Court found that “[t]hese emails—one sent on March 1, 2024, and another sent on March 4, 2024—contain[ed] misleading or inaccurate statements regarding the proposed class action settlement and associated proceedings in this case.” (Doc. 105 at 2).

On April 4, 2024, this Court entered an Order finding that these emails “materially interfere[ed] with the Court’s order to effectuate a notice plan which fairly, accurately, and reasonably informs the settlement class members of the proposed settlement terms and associated procedures to resolve their claims.” (Id. at 8). The Court further observed that “such misinformation put[] final resolution of this case in jeopardy as it risk[ed] coercion of presumptive class members to opt out without the benefit of complete and accurate

information.” (Id.). Despite the Court’s admonition, on April 9, 2024—within days of the Court’s Order—Attorneys Aughtman and Mendelsohn sent another email to their clients stating: “Bow’s defense counsel and the class action attorneys are making rigorous efforts to delay your individual claims that we continue to pursue for you.” (Doc. 109-1 at 4). This email falsely portrays the Court’s efforts to rectify Attorneys Aughtman and Mendelsohn’s misleading communications as unnecessarily “delay[ing their clients’] individual claims.”

(Id.). Worse still, on May 7, 2024, Attorneys Aughtman and Mendelsohn sent a fourth email to their clients in which they stated: “If you receive any communication regarding your pex [sic] pipe case from any company or firm other than our offices, please call us and simply forward it to us or drop by our office and we will handle the response on your behalf.” (Id. at 5). This email suggests that class members should not speak with Class

Counsel, despite the Court’s April 4 Order expressly observing that such communications are permissible. (Doc. 105 at 3). Despite the curative notice sent pursuant to the Court’s April 4, 2024 Order, the parties received, through the Court-appointed Settlement Administrator, several bulk mailings containing individual requests for exclusion. The parties represented to the Court

that the first batch of requests for exclusion was received by the Settlement Administrator on April 12, 2024. The opt-out deadline has now expired, and the parties represent that they have received a total of 322 requests for exclusion. According to the parties, 302 of these requests for exclusion were dated and signed before April 4, 2024, and thus they escaped the Court’s first curative notice. Of those 302 requests, 226 requests were dated and signed before the Settlement Administrator even issued the Court-approved class

settlement notice on March 12, 2024. Moreover, only three requests for exclusion were from individuals or entities that are not represented by Attorneys Aughtman and Mendelsohn. III. LEGAL STANDARD Federal Rule of Civil Procedure 23(d) provides, in pertinent part, that a court may issue orders “to protect class members and fairly conduct the action.” FED. R. CIV. P.

23(d)(1)(B). This Court “has both the duty and the broad authority to exercise control over a class action and to enter appropriate orders governing the conduct of counsel and parties.” Gulf Oil Co. v. Bernard, 452 U.S. 89, 100 (1981); Georgine v. Amchem Prods., 160 F.R.D. 478, 489 (E.D. Pa. 1995) (citing Gulf Oil, 452 U.S. at 100).1 Specifically, with respect to class actions, district courts have a duty to “protect both the absent class and the integrity

of the judicial process by monitoring the actions before it.” Kleiner v. First Nat’l Bank of Atlanta, 751 F.2d 1193, 1202 (11th Cir. 1985) (quoting Deposit Guaranty Nat’l Bank v. Roper, 445 U.S. 326, 331 (1980)); see also Georgine, 160 F.R.D. at 490 (“[I]t is essential that the district court closely monitor the notice process and take steps necessary to ensure that class members are informed of the opportunity to exclude themselves or to participate

in the judgment”); FED. R. CIV. P. 23(c)(2).

1 Here, and elsewhere in this Opinion, the Court cites nonbinding authority. While the Court acknowledges these cases are nonprecedential, the Court finds them persuasive. “Courts have continually held that misleading communications to class members concerning the litigation pose a serious threat to the fairness of the litigation proceedings

and violate the principle of informed consent, and the Federal Rules allow the courts to protect class members and putative class members from such communications.” Riley v. Flowers Baking Co. of Jamestown, LLC, 2015 WL 4249849, at *2 (W.D.N.C. July 13, 2015) (collecting cases). “A communication is coercive or misleading when [a party] interferes with participation by potential class members in the lawsuit or misinforms them by failing to reveal how some proposed transaction might affect their rights in the

litigation.” Id.

Free access — add to your briefcase to read the full text and ask questions with AI

Braswell v. Bow Plumbing Group, Inc., (M.D. Ala. 2024).

Braswell v. Bow Plumbing Group, Inc. (Braswell v. Bow Plumbing Group, Inc.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Deposit Guaranty National Bank v. Roper
445 U.S. 326 (Supreme Court, 1980)
Gulf Oil Co. v. Bernard
452 U.S. 89 (Supreme Court, 1981)
Kleiner v. First National Bank
751 F.2d 1193 (Eleventh Circuit, 1985)
Georgine v. Amchem Products, Inc.
160 F.R.D. 478 (E.D. Pennsylvania, 1995)