Kirchner v. Wyndham Vacation Resorts, Inc.

CourtDistrict Court, D. Delaware
DecidedSeptember 13, 2024
Docket1:20-cv-00436
StatusUnknown

This text of Kirchner v. Wyndham Vacation Resorts, Inc. (Kirchner v. Wyndham Vacation Resorts, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kirchner v. Wyndham Vacation Resorts, Inc., (D. Del. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

STEVEN ERIC KIRCHNER, ELIZABETH LEE KIRCHNER, and ROBERT GRANT WESTON, individually and on behalf of all other persons similarly situated, ivil Action No. 20-436- Plaintiffs, Civil Action No. 20-436-RGA

V. WYNDHAM VACATION RESORTS, INC., Defendant.

MEMORANDUM ORDER Before me are Plaintiffs’ motion for class certification (D.I. 112) and motion for an evidentiary hearing and for leave to file a trial plan (D.I. 134). I have considered the parties’ briefing. (D.I. 113, 120, 122, 134-36). I heard oral argument on the motion for class certification on July 22, 2024.' For the reasons set forth below, Plaintiffs’ motions are DENIED. I. BACKGROUND This putative class action arises out of alleged omissions and misrepresentations made in timeshare sales presentations by Defendant Wyndham.’ On March 27, 2020, Plaintiffs Steven Eric Kirchner and Elizabeth Lee Kirchner filed their first complaint with co-plaintiff Nazret Z. Gebremeskel on behalf of themselves and all other similarly situated people. (D.I. 1). The class allegations were limited to people who signed timeshare agreements in Tennessee and Nevada.

' Citations to the transcript of the argument, which is not yet docketed, are in the format “Hearing Tr. at.” ? Plaintiffs seek class certification based on omissions, not misrepresentations. (Hearing Tr. at 9:17-21).

The Kirchners sought to represent the class of people who had signed timeshare agreements in Tennessee, while Gebremeskel sought to represent the class of people who had signed timeshare agreements in Nevada. (/d. {| 60-61). After a dismissal under Federal Rule of Civil Procedure 9(b), Plaintiffs filed an amended complaint on April 26, 2021, substituting Gebremeskel with a new class representative, Marcia Richards, because Gebremeskel’s claims were individually settled. (See D.I. 21 4 1; see also D.I. 27). In addition to pleading additional facts to cure the Rule 9(b) defect, the Amended Class Action Complaint added a count of “fraudulent inducement by omission” and correspondingly modified the putative class to one without geographical restrictions, with all three named Plaintiffs serving as class representatives. (D.I. 27 J 65, 9298). The Kirchners continued to seek to represent the subclass of people who had signed agreements in Tennessee, while Richards sought to represent the subclass of people who had signed agreements in Nevada. (/d. {| 65-67). I dismissed Plaintiff Richards’s claims as untimely. (D.I. 44 at 6-8). Plaintiffs then filed a Second Amended Class Action Complaint, substituting Plaintiff Robert Grant Weston as an additional class representative for the national class and as the sole representative for the Nevada subclass. (D.I. 52 { 65, 67). The current operative complaint is the Corrected Third Amended Class Action Complaint (the “Third Amended Complaint”), which added additional factual pleadings. (D.I. 83). It alleges fraudulent inducement by omission, violation of Nevada’s deceptive trade practices act, and violation of Tennessee’s timeshare act. (Id. □□ 92-108). On March 27, 2023, I granted Defendant’s motion to dismiss Count II of the Third Amended Complaint. I denied Defendant’s motion to dismiss Count I. (D.I. 97 at 9-10). Plaintiffs seek to certify the following class and subclass under Rule 23(b)(3):

a. All persons who signed Wyndham timeshare agreements (without arbitration clauses and without prior Wyndham timeshare agreements) within three years prior to the filing of this suit after attending Wyndham sales presentations who requested cancellation of their contracts, were unsuccessful in obtaining rescission, and complained about sales misrepresentations.° b. All persons who signed Wyndham timeshare agreements (without arbitration clauses and without prior Wyndham timeshare agreements) in Tennessee within three years prior to the filing of this suit after attending Wyndham sales presentations who requested cancellation of their contracts, were unsuccessful in obtaining rescission, and complained about sales misrepresentations.* (D.I. 112 at 1-2). Plaintiffs seek to certify the following class under Rule 23(b)(2): All persons who signed Wyndham timeshare agreements (without arbitration clauses and without prior Wyndham timeshare agreements) within three years prior to the filing of this suit after attending Wyndham sales presentations.° (Id. at 2). Il. LEGAL STANDARD A class action is “an exception to the usual rule that litigation is conducted by and on behalf of the individual named parties only.” Comcast Corp. v. Behrend, 569 U.S. 27, 33 (2013). To qualify for this exception, a party “must affirmatively demonstrate [its] compliance” with Federal Rule of Civil Procedure 23 by a preponderance of the evidence. Reyes v. Netdeposit, LLC, 802 F.3d 469, 485 (3d Cir. 2015). Before a proposed class can be certified, plaintiffs must establish that all four prerequisites of Rule 23(a), and at least one part of Rule 23(b), are met. Johnston v. HBO Film Memt., Inc., 265 F.3d 178, 183 (3d Cir. 2001).

3] refer to this as the “Cancellation Class.” ‘T refer to this as the “Tennessee Subclass.” >| refer to this as the “Injunctive Relief Class.”

Rule 23(a) sets forth four prerequisites that must be met to obtain certification of a class: (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. See Fed. R. Civ. P. 23(a). Rule 23(b)(2) authorizes a class action if the defendant “has acted or refused to act on grounds that apply generally to the class, so that final injunctive relief. . . is appropriate respecting the class as a whole.” Sullivan v. DB Investments, Inc., 667 F.3d 273, 296 (3d Cir. 2011). Rule 23(b)(3) requires that “questions of law or fact common to class members predominate over any questions affecting only individual members, and that a class action is superior to other available methods for fairly and efficiently adjudicating the controversy.” Fed. R. Civ. P. 23(b)(3). The district court must conduct a “rigorous analysis” when determining whether Rule 23’s requirements have been met. Gen. Tel. Co. of Sw. v. Falcon, 457 U.S. 147, 161 (1982). The Third Circuit has provided detailed guidance for district courts conducting this “rigorous analysis.” See In re Hydrogen Peroxide Antitrust Litig., 552 F.3d 305 (3d Cir. 2008). A party’s assurances that it plans to meet Rule 23’s requirements are insufficient. /d. at 318. Rather, the Court is required to make a “definitive determination” that each requirement of Rule 23 has been met. Jd. at 320. To the extent factual determinations are necessary, they must be made by a preponderance of the evidence. /d.

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

Related

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
131 S. Ct. 2541 (Supreme Court, 2011)
Glenn Gates v. Rohm & Haas Co
655 F.3d 255 (Third Circuit, 2011)
Comcast Corp. v. Behrend
133 S. Ct. 1426 (Supreme Court, 2013)
Gabriel Carrera v. Bayer Corp
727 F.3d 300 (Third Circuit, 2013)
In Re Hydrogen Peroxide Antitrust Litigation
552 F.3d 305 (Third Circuit, 2009)
Reynaldo Reyes v. Netdeposit
802 F.3d 469 (Third Circuit, 2015)
In re: Lamictal Direct Purchas v.
957 F.3d 184 (Third Circuit, 2020)
In re Schering Plough Corp. Erisa Litigation
589 F.3d 585 (Third Circuit, 2009)
Sullivan v. DB Investments, Inc.
667 F.3d 273 (Third Circuit, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
Kirchner v. Wyndham Vacation Resorts, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/kirchner-v-wyndham-vacation-resorts-inc-ded-2024.