Doe v. Emory University

CourtDistrict Court, N.D. Georgia
DecidedMay 5, 2025
Docket1:20-cv-02002
StatusUnknown

This text of Doe v. Emory University (Doe v. Emory University) is published on Counsel Stack Legal Research, covering District Court, N.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Doe v. Emory University, (N.D. Ga. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

MARC SCHULTZ, individually and on behalf of all others similarly situated,

Plaintiffs,

v. CIVIL ACTION FILE NO. 1:20-CV-2002-TWT EMORY UNIVERSITY,

Defendant.

OPINION AND ORDER This is a putative class action breach-of-contract action. It is before the Court on Plaintiff Marc Schultz’s Motion for Class Certification [Doc. 77]. For the reasons set forth below, the Court dismisses this action for lack of jurisdiction and, in the alternative, DENIES Plaintiff Schultz’s Motion for Class Certification [Doc. 77]. Defendant Emory’s Motion to De-Certify the Class [Doc. 100] is DENIED as moot.1 I. Background This case arises from the closure of the Defendant Emory’s campuses

1 Because of the Eleventh Circuit’s order vacating and remanding this Court’s previous class certification order, Defendant Emory University’s (“Emory”) motion [100] to de-certify the class is denied as moot. However, the Court will consider arguments raised in the briefing of that motion, as anticipated by the Eleventh Circuit. , No. 23- 12929, 2024 WL 4534428, at *6 (11th Cir. Oct. 21, 2024)(“On remand, the district court may properly consider any new materials subsequently supplemented by the pending motion to decertify and their applicability to any of Rule 23(b)(3)’s requirements.”). upon the arrival of the COVID-19 pandemic in March 2020. Emory closed its campuses in the spring and fall semesters of 2020. (Am. Compl. ¶¶ 15–18, 88 [Doc. 48].) Plaintiff Marc Schultz is the father of a former Emory student who

was enrolled full-time in classes in the spring and fall semesters of 2020. ( ¶ 12.) For those semesters, Emory refunded “student accounts with a calculated amount of unused housing, dining, athletic fees, activity fees, parking fees, and other fees unrelated to academic instruction,” but it did not refund tuition and certain other fees related to lost services. ( ¶¶ 89– 94.) Schultz alleges that “while [he] and Class members paid for students’ in- person access to renowned faculty as essential to the Emory experience,

Defendant excluded students from such access for the Spring 2020 and Fall 2020 semesters.” ( ¶ 18.) Schultz’s Amended Complaint seeks relief on two claims: (1) breach of implied contract and (2) money had and received. ( ¶¶ 109–23.) On June 15, 2023, the Court granted in part Schultz’s Motion to Certify Class, but it ordered Schultz to submit a detailed plan for class notification and

management. (June 15, 2023, Op. & Order, at 29–30 [Doc. 98].) In July 2023, Schultz filed the requested plan. [Doc. 99]. Emory then filed a response to that plan [Doc. 100], which this Court construed [Doc. 101] as a Motion to De- Certify the Class. In September 2023, the Eleventh Circuit granted permission [Doc. 102] for an interlocutory appeal of Schultz’s Motion to Certify the Class. The Eleventh Circuit subsequently vacated and remanded this Court’s 2 order granting in part the Motion to Certify Class. , 2024 WL 4534428, at *6 (11th Cir. Oct. 21, 2024). It found two errors in this Court’s reasoning: (1) it was an error to find that the Rule 23(b)(3)

predominance inquiry “ that damages . . . be measurable on a classwide basis through use of a common methodology,” at *5 (emphasis added), and (2) it was an error to place the burden on Emory rather than Schultz to establish whether damages are capable of classwide rather than individual determination, at *6. In light of the Eleventh Circuit’s order, this Court is tasked with re-evaluating Schultz’s Motion to Certify Class [Doc. 77]. Although the Motion to De-Certify Class is procedurally moot, the

Eleventh Circuit noted that this Court “may properly consider any new materials subsequently supplemented by the pending motion to decertify and their applicability to any of Rule 23(b)(3)’s requirements.” , 2024 WL 4534428, at *6. In other words, in re-evaluating Schultz’s Motion to Certify Class, this Court may evaluate the arguments presented by the parties as part of their briefing on the Motion to De-Certify Class.

Most recently, in supplemental briefing regarding the effect of the Eleventh Circuit’s opinion, Emory requested that this Court reconsider whether Schultz has standing to pursue his existing claims, citing a new wave of case law handed down since the Court first considered the issue of standing. (Def.’s Post-Remand Suppl. Br. at 2–3 [Doc. 127].) The Court afforded Schutlz an opportunity to respond in a reply brief, which Schultz timely filed. ( 3 Pl.’s Reply Br. to Def.’s Post-Remand Suppl. Br. [Doc. 130].) II. Legal Standard Federal Rule of Civil Procedure 23(c)(1)(A) provides that a court must

“[a]t an early practicable time after a person sues or is sued as a class representative . . . determine by order whether to certify the action as a class action.” Fed. R. Civ. P. 23(c)(1)(A). Courts must first determine whether a plaintiff has standing to sue. , 977 F.3d 1039, 1046 (11th Cir. 2020) (quoting , 221 F.3d 1266, 1279 (11th Cir. 2000)). Article III extends the judicial power of federal courts only to “cases” and “controversies”

between parties. , 578 U.S. 330, 337 (2016) (quoting U.S. Const. art. III, §§ 1–2). To ensure that federal courts adjudicate only “cases” and “controversies,” a plaintiff must establish that he has standing to sue by showing: (1) [he] has suffered an “injury in fact” that is (a) concrete and particularized and (b) actual or imminent, not conjectural or hypothetical; (2) the injury is fairly traceable to the challenged action of the defendant; and (3) it is likely, as opposed to merely speculative, that the injury will be redressed by a favorable decision. , 693 F.3d 1317, 1323 (11th Cir. 2012) (quoting , 528 U.S. 167, 180–81 (2000)). In a putative class action, at least one named plaintiff must have standing as to each claim asserted. , 221 F.3d at 1279. 4 If courts determine that the named plaintiffs have standing, they may then determine whether a proposed class is “adequately defined and clearly ascertainable.” , 986 F.3d 1296, 1302 (11th Cir. 2021)

(quoting , 691 F.3d 1302, 1304 (11th Cir. 2012)). If the standing and ascertainability requirements are met, courts must then assess whether the class representatives have satisfied the four requirements outlined in Rule 23(a): (1) the class is so numerous that joinder of all members is impracticable;

(2) there are questions of law or fact common to the class;

(3) the claims or defenses of the representative parties are typical of the claims or defenses of the class; and

(4) the representative parties will fairly and adequately protect the interests of the class. Fed. R. Civ. P. 23(a). Lastly, the proposed class must also satisfy at least one of the alternative requirements in Rule 23(b). , 648 F. App’x 930, 933 (11th Cir. 2016). The Plaintiff’s Motion to Certify specifically contends that Rule 23(b)(3) is satisfied. (Br. in Supp. of Pl.’s Mot. to Certify Class, at 13–20 [Doc.

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