Gur-Ravantab v. Georgetown University

CourtDistrict Court, District of Columbia
DecidedJuly 16, 2024
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. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

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

Plaintiffs,

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

GEORGETOWN UNIVERSITY,

Defendant.

MEMORANDUM ORDER

Plaintiffs Emir Gur-Ravantab and Emily Lama, former students of Georgetown

University, sued the University over its COVID policies. First Amend. Compl. (FAC) at 1, ECF

No. 12. They challenged the University’s decision to switch to online-only education in the

Spring 2020 semester. Id. ¶¶ 37–40. But they did not do so alone. Instead, they brought a

putative class action, claiming to represent all students who were enrolled at Georgetown at that

time. Id. ¶ 61. The Court denied their first motion for class certification. See Gur-Ravantab v.

Georgetown Univ., 345 F.R.D. 1 (D.D.C. 2023). Now, they move to substitute new class

representatives and seek “preliminary approval of a class action settlement.” ECF No. 67. For

the reasons below, the Court grants that motion.

I.

COVID-19 took the world by storm in early 2020. Gur-Ravantab, 345 F.R.D. at 3. To

manage the crisis, and to mitigate the risk students would spread the virus, Georgetown shifted

its lessons to fully remote instruction. FAC ¶¶ 37–40. It did so just after Spring Break, id. ¶ 37,

meaning that about half the semester was remote, id. ¶ 40. Plaintiffs are former Georgetown students who claim they were stiffed. They say they

were promised in-person education during the Spring 2020 semester. FAC ¶ 17. But that’s not

what they got. Instead, the University gave them remote education during the Spring 2020

semester. Id. ¶ 38. They claim that a remote education is worth less than an in-person one, Gur-

Ravantab, 345 F.R.D. at 3, but that Georgetown never paid them the difference, FAC ¶ 41. In

essence, it took their money, but gave them less than they paid for. They thus brought three

contract claims on their own behalf as well as that of all others similarly situated. Id. ¶¶ 70–131.

Plaintiffs moved once before to certify their class of undergraduate students; the Court

denied them. See generally Gur-Ravantab, 345 F.R.D. 1. Now, the parties have chosen to settle.

Plaintiffs have therefore filed an omnibus motion doing several things. Mem. of Law in Supp. of

Mot. (Mot.), ECF No. 67-12. 1 First, it seeks to substitute two new class representatives for the

old. Id. at 4–6, 23. Second, it seeks what it calls preliminary approval of the proposed

settlement. Id. at 6–15. Third, it seeks what it calls “provisional certification” of the putative

settlement class. Id. at 15–23. Fourth, it seeks approval of a plan to notify absent class members

of this lawsuit. Id. at 23–24. And last, it asks the Court to name Plaintiffs’ counsel as class

counsel. Id. at 24–25.

II.

First, the parties jointly seek to add two new named Plaintiffs, who will serve as class

representatives in place of Gur-Ravantab. Intervention is governed by Federal Rule of Civil

1 The motion itself makes no mention of Emily Lama or the graduate student class she was originally held out as representing. Presumably, Lama’s individual claims remain live. That said, the parties have barely mentioned her since Plaintiffs filed their Motion to Certify Class in June 2023. She filed no motion to certify her own graduate student class, and the parties have taken no steps to litigate her individual claims since then. And she is barely mentioned in the settlement agreement, save for having a service award earmarked for her.

2 Procedure 24. Fed. R. Civ. P. 24. In general, the Court “must” permit a party to intervene if he

possesses “an interest relating to the property or transaction that is the subject of the action” and

“disposing of the action may as a practical matter impair or impede [his] ability to protect [his]

interest.” Fed. R. Civ. P. 24(a)(2). Or the Court “may” permit intervention, if it so chooses,

when a party “has a claim or defense that shares” “a common question of law or fact” “with the

main action.” Fed. R. Civ. P. 24(b)(1)(B).

Next, the parties seek “preliminary approval of [the] class action settlement.” Mot. at 1.

The Federal Rules of Civil Procedure does not use this term. Rather, before certifying a

settlement class and approving a class settlement, the Court “must direct notice in a reasonable

manner to all class members who would be bound by the proposal.” Fed. R. Civ. P. 23(e)(1)(B).

And to warrant such notice, the parties must “show[] that the court will likely be able to”

(1) “approve the propos[ed settlement agreement] under Rule 23(e)(2)” and (2) “certify the class

for purposes of” the settlement agreement. Id. That means confirming that the Court would

“likely” conclude that the agreement is “fair, reasonable, and adequate” on its terms, Fed. R. Civ.

P. 23(e)(2), and that the Court would “likely” agree that the proposed class meets the

certification criteria in Rule 23(a) and (b). This is not an approval of the settlement—instead, it

is only an anticipatory judgment about what the Court is “likely” to do. Cf. United States v.

Seefried, --- F. Supp. 3d ---, 2024 WL 1299371, at *5 (D.D.C. 2024).

And the Court has a special duty in assessing proposed class settlements. See In re Gen.

Motors Corp. Pick-Up Truck Fuel Tank Prods. Liab. Litig., 55 F.3d 768, 785 (3d Cir. 1995); see

also Briseño v. Henderson, 998 F.3d 1014, 1022 (9th Cir. 2021) (describing district court’s

special “independent obligation” in this area). A class settlement is not like an ordinary

settlement. Usually, a settlement between the parties settles things just between the parties. In a

3 class action, however, the settlement settles matters between the Defendant and the entire class—

even those members who are not present and may not know about the agreement. So the usual

permissive philosophy toward settlements, that they are up to the parties’ discretion, does not

apply in the class action context. Otherwise, the risks for chicanery are too great. Lane v.

Facebook, Inc., 696 F.3d 811, 819 (9th Cir. 2012) (“[W]e will not affirm if it appears that the

district court did not evaluate the settlement sufficiently to account for the possibility that class

representatives and their counsel have sacrificed the interests of absent class members for their

own benefit.”). The Court therefore “bear[s] the important responsibility of protecting absent

class members” in assessing the proposed settlement agreement. In re Pet Food Prods. Liab.

Litig., 629 F.3d 333, 349 (3d Cir. 2010). The Federal Rules of Civil Procedure implement this

rule through detailed requirements in Rule 23(e). Fed.

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