Mitchell v. H & R BLOCK, INC.

783 So. 2d 812, 2000 WL 1716953
CourtSupreme Court of Alabama
DecidedNovember 17, 2000
Docket1971582
StatusPublished
Cited by14 cases

This text of 783 So. 2d 812 (Mitchell v. H & R BLOCK, INC.) is published on Counsel Stack Legal Research, covering Supreme Court of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mitchell v. H & R BLOCK, INC., 783 So. 2d 812, 2000 WL 1716953 (Ala. 2000).

Opinions

The plaintiffs appeal from the trial court's order denying a class certification. They argue that the trial court abused its discretion in denying the certification. Because the trial court incorrectly adjudicated an issue of law in its analysis done pursuant to Rule 23(b)(3), Ala.R.Civ.P., and because it provided no analysis whatever under Rule 23(a), we reverse the order and remand.

The Mitchells sued H R Block, Inc., and Ruth Wren on behalf of themselves and sought to be allowed to represent a class composed of all Alabama residents similarly situated. The Mitchells' claims arose out of a tax-refund-anticipation-loan ("RAL") program offered through H R Block's company-owned and franchised offices. The Mitchells allege that H R Block habitually received hidden profits from tax-refund-anticipation loans that were obtained on behalf of its clients from third-party lenders. The Mitchells originally stated four causes of action: 1) breach of fiduciary duty, 2) fraudulent suppression, 3) fraudulent misrepresentation, and 4) unjust enrichment. However, the Mitchells sought class certification only as to the breach-of-fiduciary duty and unjust-enrichment claims. The trial court denied class certification, based on its finding that the contract used in the RAL program did not establish a fiduciary relationship between H R Block and the Mitchells.

The trial court's order denying class certification discusses the law on class certification; we quote that order here, in pertinent part:

"When seeking the certification of a would-be class, a plaintiff bears the burden of proving that every requirement of Rule 23 has been satisfied. See Ex Parte Mercury Finance Corp., 715 So.2d 196 (Ala. 1997); Ex parte Equity National Life Ins. Co., 715 So.2d 192 (Ala. 1997); Butler v. Audio/Video Affiliates, Inc., 611 So.2d 330, 331 (Ala. 1992). Moreover, in deciding whether this burden has been carried, a court must conduct a `rigorous analysis.' See Ex parte American Bankers Life Assurance Co., *Page 814 715 So.2d 186 (Ala. 1997); Ex parte Equity National Life Ins. Co., [supra]; see also General Telephone Co. v. Falcon, 457 U.S. 147, 161 (1982). Accord, Castano v. American Tobacco Co., 84 F.3d 740, [740] (5th Cir. 1996) (courts `must conduct a rigorous analysis of the [R]ule 23 prerequisites before certifying a class.')1

"In the instant case, the plaintiffs must prove that they meet each of the four Rule 23(a) prerequisites:

"(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.

"Ala.R.Civ.P. 23(a). See also Rowan v. First Bank of Boaz, 476 So.2d 44, 46 (Ala. 1985). `Rule 23(a) acts as a lens through which the Court looks to ensure that the interests and claims of the representative plaintiff [match] those of the putative class. The duty of the Court is to encompass and enforce the understanding that "a class representative must be part of the class and `possess the same interest and suffer the same injury' as the class members." Buford v. H R Block, Inc., 168 F.R.D. 340, 347 (S.D.Ga. 1996), aff'd, 117 F.3d 1433 (11th Cir. 1997).

"If the plaintiffs clear the four Rule 23(a) hurdles, a higher hurdle awaits: they must prove that the putative class meets the additional criteria imposed by Rule 23(b)(3). The text of that familiar provision reads as follows:

"`[The plaintiffs must prove] that the questions of law or fact common to the members of the class predominate over any questions affecting only individual members, and that a class action is superior to other available methods for the fair and efficient adjudication of the controversy.'

Ala.R.Civ.P. 23(b)(3).

"Rule 23(b)(3) covers situations where `class-action treatment is not as clearly called for as in those [situations] described' by Rule 23(b)(1) and 23(b)(2). Rule 23, Advisory Committee's Official Note, 39 F.R.D. 98, 102 (1966). As its text indicates, it imposes two distinct standards: (1) the common issues must `predominate' over `any questions' affecting individual class members; and (2) a class action approach must be `superior to other available methods' for handling the putative class members' claims. The predominance and superiority requirements `"reflect the fact that special caution must be exercised in [Rule 23(b)(3)] class actions . . . because of the loose affiliation among the class members, which is thought to magnify the risks inherent in any representative action."' Buford, 168 F.R.D. at 355 (quoting Wright Miller, 7A Federal Practice Procedure § 1777) (emphasis added) (internal quotation marks omitted). As with all class action requirements, the plaintiffs have the burden of proof on the issues of predominance and superiority. See Bradley v. Harrelson, 151 — F.R.D. 422, 425 (M.D.Ala. 1993); Jordan v. Swindall, 105 F.R.D. 45, 46 (M.D.Ala. 1985). See also *Page 815 General Telephone Co., 457 U.S. at 159 n. 15 (a finding of predominance under Rule 23(b)(3) requires `[s]ignificant proof')."

Although an order denying class certification is an interlocutory order, it is appealable because it "finally determines a claim of right separate from and collateral to the rights asserted in the cause of action" and makes further judicial proceedings in the action ineffective. Butler v. Audio/Video Affiliates, Inc., 611 So.2d 330, 331 (Ala. 1992). The question whether to certify a class is in the sound discretion of the trial court, and, so long as the trial court considers the correct criteria in making its determination, we review its ruling only to determine whether the trial court abused its discretion. Adamsv. Robertson, 676 So.2d 1265, 1270 (Ala. 1995), cert. dismissed asimprovidently granted, 520 U.S. 83 (1997); First Alabama Bank ofMontgomery, N.A. v. Martin, 425 So.2d 415, 423 (Ala. 1982), cert.denied, 461 U.S. 938 (1983).

I. Rule 23(b)(3)
The Mitchells contend that the trial court abused its discretion in denying class certification as to the claims alleging breach of fiduciary duty and unjust enrichment.

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Mitchell v. H & R BLOCK, INC.
783 So. 2d 812 (Supreme Court of Alabama, 2000)

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Bluebook (online)
783 So. 2d 812, 2000 WL 1716953, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mitchell-v-h-r-block-inc-ala-2000.