Marty Stanifer v. Louisville and Jefferson County Metropolitan Sewer District

CourtCourt of Appeals of Kentucky
DecidedJanuary 19, 2023
Docket2022 CA 000704
StatusUnknown

This text of Marty Stanifer v. Louisville and Jefferson County Metropolitan Sewer District (Marty Stanifer v. Louisville and Jefferson County Metropolitan Sewer District) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Marty Stanifer v. Louisville and Jefferson County Metropolitan Sewer District, (Ky. Ct. App. 2023).

Opinion

RENDERED: JANUARY 20, 2023; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2022-CA-0704-ME

MARTY STANIFER APPELLANT

APPEAL FROM JEFFERSON CIRCUIT COURT v. HONORABLE MITCH PERRY, JUDGE ACTION NO. 17-CI-001658

LOUISVILLE AND JEFFERSON COUNTY METROPOLITAN SEWER DISTRICT AND UNKNOWN MSD PUMP OPERATOR APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: THOMPSON, CHIEF JUDGE; CALDWELL AND GOODWINE, JUDGES.

THOMPSON, CHIEF JUDGE: Marty Stanifer appeals from an order denying his

motion for class certification. Appellant argues that the trial court abused its

discretion in denying his motion to certify a class action. We find no error and

affirm. FACTS AND PROCEDURAL BACKGROUND

In April of 2015, Louisville, Kentucky was subjected to a large

amount of rainfall which caused significant flooding in the area. In March of

2017, Appellant filed the underlying lawsuit on behalf of himself and others

similarly situated. He claimed that a water pumping station near his home

malfunctioned and either caused or exacerbated the significant flooding which

occurred in 2015, and that this flooding caused property damage. It was later

revealed that this pumping station was not part of the storm water drainage system,

but was a sewer pumping station. Appellant later amended his complaint to allege

that the sewer pumping station was not working properly and caused a sewage

overflow. He went on to claim that this overflow caused or exacerbated the

flooding and led to the property damage.

In February of 2022, Appellant moved to have his cause of action

certified as a class action. He wanted to include in the class people who suffered

property damage from the flooding and who were within his neighborhood. He

specifically identified sixteen other people who suffered damages from the

flooding. He also identified around 150 other individual properties that were

within the geographical area in which he was basing his class membership.1 The

1 The geographical area was based on his expert’s opinion as to where a sewage overflow could have occurred based on a schematic and layout of the sewage drainage system. Appellant’s expert did not opine as to whether a sewage overflow actually occurred, only that it was possible,

-2- Louisville and Jefferson County Metropolitan Sewer District opposed the motion

and argued that Appellant’s class was too speculative.

A hearing was held on the issue in May of 2022. An order denying

the class certification motion was entered in June of 2022, and this appeal

followed.2

ANALYSIS

The decision to deny class certification is reviewed for an abuse of discretion. The test for abuse of discretion is whether the trial judge’s decision was arbitrary, unreasonable, unfair, or unsupported by sound legal principles. As this Court undertakes its review, [w]e must focus our analysis on this limited issue [of class certification] and in so doing scrupulously respect the limitations of the crossover between (1) reviewing issues implicating the merits of the case that happen to affect the class-certification analysis and (2) limiting our review to the class-certification issue itself.

Manning v. Liberty Tire Services of Ohio, LLC, 577 S.W.3d 102, 109-10 (Ky. App.

2019) (internal quotation marks, footnotes, and citations omitted). “In Kentucky,

CR 23.01 and 23.02 govern class certification. Taken together, the rules provide a

comprehensive roadmap to class certification. The mandates of both rules must be

and he would need to conduct further testing and computer modeling before he could express such an opinion. 2 Kentucky Rule of Civil Procedure (CR) 23.06 allows for an immediate appeal from an order granting or denying class certification.

-3- satisfied before a class may be certified. The party seeking certification bears the

burden of proof.” Id. at 110 (citation omitted).

Subject to the provisions of Rule 23.02, one or more members of a class may sue or be sued as representative parties on behalf of all only if (a) the class is so numerous that joinder of all members is impracticable, (b) there are questions of law or fact common to the class, (c) the claims or defenses of the representative parties are typical of the claims or defenses of the class, and (d) the representative parties will fairly and adequately protect the interests of the class.

CR 23.01. “The four requirements in CR 23.01 to maintaining a class action can

be summed up as numerosity, commonality, typicality, and adequacy of

representation requirements.” Hensley v. Haynes Trucking, LLC, 549 S.W.3d 430,

442-43 (Ky. 2018) (footnote and citation omitted) (emphasis in original).

Rule 23 requires a showing that questions common to the class predominate, not that those questions will be answered, on the merits, in favor of the class. Federal circuit courts have addressed the issue even more bluntly: The determination [of] whether there is a proper class does not depend on the existence of a cause of action. A suit may be a proper class action, conforming to Rule 23, and still be dismissed for failure to state a cause of action.

Id. at 437 (internal quotation marks, footnotes, and citations omitted) (emphasis in

original).

In the case at hand, the trial court held that Appellant had failed to

meet the first two factors of CR 23.01, numerosity and commonality. We will first

-4- address numerosity. The trial court held that Appellant’s identification of around

150 different properties, but only seventeen individuals,3 that could have been

affected by the flooding is not definitive enough to show an impracticality of

joinder.

There is no precise size or number of class members that automatically satisfies the numerosity requirement. Whether a number is so large that it would be impracticable to join all parties depends not upon any magic number or formula, but rather upon the circumstances surrounding the case. The substantive nature of the claim, the type of the class action, and the relief requested bear on . . . the necessary showing of numerosity in relation to impracticability of joinder. Practicability of joinder also depends on the size of the class, the ease of identifying its members and determining their addresses, facility of making service on them, and their geographic dispersion. Impracticability does not mean impossibility. The class representative need show only that it is extremely difficult or inconvenient to join all members of the class.

Hensley, 549 S.W.3d at 443 (internal quotation marks, footnotes, and citations

omitted) (emphasis in original).

Keeping in mind that we review this issue for an abuse of discretion,

we find no error. The evidence so far indicates that the geographic area that

includes the 150 properties is where a sewage overflow could have occurred, not

that one did occur there. The evidence also shows that not all of those 150

3 The sixteen individuals mentioned previously and Appellant himself.

-5- properties actually incurred flood damage. Finally, there is no evidence that the

people who currently own those 150 properties also owned the properties in 2015

when the flooding occurred. The court held that the seventeen individuals

identified were not numerous enough to make joinder impractical and the other

150 property owners were too speculative.

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Related

Nebraska Alliance Realty Co. v. Brewer
529 S.W.3d 307 (Court of Appeals of Kentucky, 2017)
Manning v. Liberty Tire Servs. of Ohio, LLC
577 S.W.3d 102 (Court of Appeals of Kentucky, 2019)
Hensley v. Haynes Trucking, LLC
549 S.W.3d 430 (Missouri Court of Appeals, 2018)

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