Gur-Ravantab v. Georgetown University

CourtDistrict Court, District of Columbia
DecidedOctober 5, 2023
DocketCivil Action No. 2022-1038
StatusPublished

This text of Gur-Ravantab v. Georgetown University (Gur-Ravantab v. Georgetown University) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gur-Ravantab v. Georgetown University, (D.D.C. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

EMIR GUR-RAVANTAB, individually and on behalf of all others similarly situated, et al.,

Plaintiffs, Case No. 1:22-cv-01038 (TNM) v.

GEORGETOWN UNIVERSITY,

Defendant.

MEMORANDUM ORDER

Emir Gur-Ravantab is a graduate of Georgetown University, Class of 2020. During the

March of his final semester, the COVID-19 pandemic changed everything. Like many other

schools, Georgetown moved to fully virtual instruction for the rest of the term. But Gur-

Ravantab argues that this breached his contract with Georgetown. He claims he paid a set tuition

for a set form of instruction: in-person, face-to-face teaching.

He now sues Georgetown for the difference in value between the education he paid for

and the one he received. And he also asks to certify a class of similarly situated Plaintiffs. Gur-

Ravantab’s Motion for Class Certification is now ripe. But he is not an adequate representative

of the class he proposes to certify. Nor is he even a member of it. So the Court denies his

motion. Gur-Ravantab may continue his suit, but only on his own behalf.

I.

Gur-Ravantab is a former student of Georgetown University, First Am. Compl. (FAC)

¶ 44, ECF No. 12, which he attended from 2016 through 2020, Pl.’s Student Acct. Stmt., ECF

No. 43-8. Georgetown provided him various documents before his enrollment, and he alleges

that these formed a contract between himself and Georgetown. Under that contract, he paid tuition in exchange for a guarantee of “in-person classroom learning[] and other services.” FAC

¶ 10. But, he argues, Georgetown did not fulfill its end of the bargain.

In March 2020, the COVID-19 pandemic swept the nation. In response, Georgetown

announced that it was transitioning to remote instruction for the rest of the Spring 2020 semester.

FAC ¶ 37. Gur-Ravantab alleges that there is a material difference in value between in-person

and remote instruction. Mot. for Class Cert. at 16–18, ECF No. 40-9. And despite having

transitioned to remote instruction, Georgetown has never paid him the difference. FAC ¶ 41.

Gur-Ravantab therefore sues for compensatory and punitive damages, along with restitution, on

claims that Georgetown breached both an express and an implied contract, id. ¶¶ 70–113, and

that it was unjustly enriched by its conduct, id. ¶¶ 114–31.

But Gur-Ravantab does not sue only on his own behalf. He has also moved to certify a

class comprising “[a]ll undergraduate students enrolled in classes at Georgetown University

during the Spring 2020 semester who paid tuition and Mandatory Fees.” Mot. for Class Cert. at

1. That class would, as Gur-Ravantab tells it, cover roughly 7,300 other current and former

Georgetown students. Id. at 6. Gur-Ravantab argues that, like him, each of the other class

members formed a contract with Georgetown upon enrollment and that each of them suffered an

identical breach. See id. at 7–8.

II.

“It is a principle of general application in Anglo-American jurisprudence that one is not

bound by a judgment . . . in a litigation in which he is not designated as a party.” Hansberry v.

Lee, 311 U.S. 32, 40 (1940). That rule exists to protect individuals’ due process rights. Id. at 41.

But that “principle of general application” has certain important exceptions, such as the “class or

representative suit,” i.e., the class action. Id. (internal quotation marks omitted).

2 Even in a class action, though, the due process rights of absent plaintiffs must be

protected. So, to ensure that the Due Process Clause is enforced even during a class action, the

Supreme Court issued Federal Rule of Civil Procedure 23. That rule contains certain

requirements for all class actions, see Fed. R. Civ. P. 23(a), which help ensure that the absent

class members are protected and that no one has his rights trammeled on by a stranger suing on

his behalf.

Rule 23(a)’s requirements are as simple as they are essential. The first two requirements

go to the class itself: First, the class must be big—specifically, so big “that joinder of all

members is impracticable.” Fed. R. Civ. P. 23(a)(1). If it is reasonably feasible for the whole

class to directly participate in the lawsuit, they should do so. Active involvement is preferred to

sitting on the sidelines. And second, there must be “questions of law or fact common to the

class.” Fed. R. Civ. P. 23(a)(2). In other words, there needs to be a reason to proceed as a class

action, some kind of common question that a court can solve for all the parties at once. Wal-

Mart Stores, Inc. v. Dukes, 564 U.S. 338, 350 (2011).

The latter two requirements then go to the class representative: Third, whoever seeks to

represent the class needs to have “claims or defenses” that are “typical of the claims or defenses

of the class.” Fed. R. Civ. P. 23(a)(3). There needs to be a reason to believe that the plaintiff’s

claims are “so interrelated” with those of the class that the plaintiff is a good stand-in for the

class members in their absence. Gen. Tel. Co. of the Sw. v. Falcon, 457 U.S. 147, 157 n.13

(1982). And last, the class representative must be able to “fairly and adequately protect the

interests of the class.” Fed. R. Civ. P. 23(a)(4). He cannot, for example, have a conflict of

interest that pits him against other class members, Amchem Prods., Inc. v. Windsor, 521 U.S.

591, 625 (1997), and his attorneys must be competent enough to handle the tough demands of a

3 class action. Id. at 626 n.20. These requirements are known as “numerosity,” “commonality,”

“typicality,” and “adequacy,” respectively.

Courts have also recognized another implied requirement that undergirds the Rule 23(a)

requirements. The Supreme Court has “repeatedly held” that “a class representative must be part

of the class and possess the same interest and suffer the same injury as the class members.”

E. Tex. Motor Freight Sys. Inc. v. Rodriguez, 431 U.S. 395, 403 (1977) (internal quotation marks

omitted). It has, however, been opaque about where that rule comes from. On various

occasions, it has identified no fewer than five different sources for that rule. E.g., McCabe v.

Atchison, Topeka, & Santa Fe Ry. Co., 235 U.S. 151, 162 (1914) (general principles of equity);

Schlesinger v. Reservists Comm. to Stop the War, 418 U.S. 208, 216 (1974) (Article III

standing); Kremens v.

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Related

McCabe v. Atchison, Topeka & Santa Fe Railway Co.
235 U.S. 151 (Supreme Court, 1914)
Hansberry v. Lee
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Schlesinger v. Reservists Committee to Stop the War
418 U.S. 208 (Supreme Court, 1974)
Sosna v. Iowa
419 U.S. 393 (Supreme Court, 1975)
Kremens v. Bartley
431 U.S. 119 (Supreme Court, 1977)
East Texas Motor Freight System, Inc. v. Rodriguez
431 U.S. 395 (Supreme Court, 1977)
General Telephone Co. of Southwest v. Falcon
457 U.S. 147 (Supreme Court, 1982)
Amchem Products, Inc. v. Windsor
521 U.S. 591 (Supreme Court, 1997)
Wal-Mart Stores, Inc. v. Dukes
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Hassine v. Jeffes
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Saylor v. Handley Motor Company
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Maxwell v. Gallagher
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Coleman v. District of Columbia
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