Moore v. Westgate Resorts Ltd., L.P.

District Court, E.D. Tennessee·Decided September 16, 2025·No. 3:18-cv-00410·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE AT KNOXVILLE MARILYN MOORE et al., individually and ) on behalf of all others similarly situated, ) ) Plaintiffs, ) ) v. ) No. 3:18-CV-00410-DCLC-JEM ) WESTGATE RESORTS, LTD., et al., ) ) Defendants. )

MEMORANDUM OPINION AND ORDER This matter is before the Court on Plaintiffs’ Motion for Class Certification and Appointment of Class Counsel [Doc. 124] Plaintiffs’ Memorandum of Law [Doc. 126], Defendants’ Response in Opposition [Doc. 146], and Plaintiffs’ Reply [Doc. 157]. For the reasons herein, the Court will deny Plaintiffs’ motion with leave to renew. I. BACKGROUND Defendants sell timeshare units to vacationers at Westgate Smokey Mountain Resort in Gatlinburg, Tennessee, and Plaintiffs Marilyn Moore, Ryan and Laura Spado, Ellen Gilliland,1 Gerold Gallegos, Deborah Campbell, Brian and Danyelle Miller, and Tonya Melfi, at various points, bought timeshares from Defendants at this resort. [Third Am. Compl., Doc. 98, ¶¶ 39– 40, 61, 68, 79, 90, 99, 107]. Plaintiffs allege that Defendants used “high-pressure sales tactics” to snooker them into purchasing their timeshares. [Id. ¶ 36; see id. at 1–2, 13–14 ]. Specifically, they claim that Defendants invite vacationers like themselves to tour the resort, but the tours turn into multi-hour sales pitches “designed to ensure that they do not leave without purchasing

1 Plaintiffs have notified the Court of the death of Plaintiff Larry Gilliland. [Pls.’ Notice, Doc. 197]. a timeshare property.” [Id. ¶ 40]. During one of these sales pitches, for example, Defendants’ agents allegedly refused to allow Mr. Gallegos and Ms. Campbell to leave to take prescription medications, and they “eventually succumbed to the high-pressure tactics” as the “closing process stretched beyond 10:00 p.m.” [Id. ¶¶ 88–89].

According to Plaintiffs, Defendants “train[] [their] agents to make misrepresentations and omissions during the sales process.” [Id. ¶ 31]. For instance, Defendants’ agents allegedly tell prospective purchasers that they can use their timeshare units anytime so long as they book them twenty-four hours in advance, but after purchasing a unit, purchasers are unable to book their units even when they give as much as twelve months’ notice. [Id. ¶¶ 44–45]. Plaintiffs claim that the units are actually unavailable to purchasers—and that Defendants know they are unavailable but do not say so upfront—because Defendants sell them to multiple buyers at a time, rent them to non-owners, use them as model units, and close them for maintenance. [Id. ¶ 36]. In short, purchasers “will not be able to use their timeshare purchase as advertised or

as would be reasonably expected—or sometimes at all,” [id.]; instead, they are at the mercy of a “floating use plan,” which Defendants do “not adequately describe to timeshare purchasers,” [id. ¶ 51]. The “floating use plan” allegedly “gives owners the right to use a certain type of unit, subject to availability.” [Id. ¶ 49]. And although state law requires timeshare developers like Defendants to disclose to purchasers that they have a legal right to rescind their purchase agreements, Plaintiffs allege that Defendants hide these disclosures in a folio, in which they provide purchasers with documentation of their purchase but conceal their right of recission inside a “secret pocket.” [Id. ¶¶ 2, 36b, 55]. Plaintiffs have now filed a proposed class-action suit against Defendants in this Court, seeking to sue on behalf of themselves and all others similarly situated to them. Plaintiff bring claims against Defendants for violations of the Tennessee Time-Share Act of 1981, Tennessee Code Annotated § 66-32-101 et seq. (Counts One and Two), unjust enrichment (Count Three),

fraudulent misrepresentation by omission (Count Four), fraud in the inducement (Count Five), negligent misrepresentation by omission (Count Six), breach of the implied covenant of good faith and fair dealing (Count Seven), breach of contract (Count Eight), and civil conspiracy (Count Nine). Defendants moved to dismiss these claims, and the Court granted dismissal of some of them: Counts One and Eight in their entireties and Counts Two, Three, Four, Five, Six, and Nine only as to Ms. Moore, Mr. Spado, and Ms. Spado. [Mem. Op. & Order, Doc. 185, at 50–51]. As to the counts that survived dismissal, Plaintiffs move for class certification under Federal Rule of Civil Procedure 23, and they propose the following class for certification: “All residents of the United States and its territories who purchased from Westgate an All Season

‘floating use plan’ vacation timeshare property at the Westgate Smoky Mountain Resort at Gatlinburg from September 25, 2008 through the date of class certification.” [Pls.’ Mem. Supporting Class Certification, Doc. 124-1, at 20]. The parties have now fully briefed Plaintiffs’ motion for class certification. II. LEGAL STANDARD Rule 23 governs class-action suits. A class-action suit under Rule 23 is “an exception to the usual rule that litigation is conducted by and on behalf of the individual named parties only,”

Califano v. Yamasaki, 442 U.S. 682, 700–01 (1979), and it “‘economiz[es] on the expense of litigation’ by resolving key issues in one stroke,” Speerly v. Gen. Motors, LLC, 143 F.4th 306, 321 (6th Cir. 2025) (quotation omitted). Under Rule 23, the plaintiff must first demonstrate:

(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.

Fed. R. Civ. P. 23(a). Second, the plaintiff must satisfy one of Rule 23(b)’s three criteria. Wal- Mart Stores, Inc. v. Dukes, 564 U.S. 338, 345 (2011). Plaintiffs here seek certification under Rule 23(b)(3), which requires “the court [to] find[] that the 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). III. ANALYSIS “[C]ertification is proper only if ‘the trial court is satisfied, after a rigorous analysis, that the prerequisites of Rule 23(a) have been satisfied.’” Wal-Mart, 564 U.S. at 350–51 (quotation omitted). One of those prerequisites is commonality, i.e., the requirement that the plaintiff must identify “questions of law or fact common to the class.” Fed. R. Civ. P. 23(a)(3). “Commonality requires the plaintiff to demonstrate that the class members ‘have suffered the same injury,’” but the plaintiff must do more than show “merely that they have all suffered a violation of the same provision of law.” Wal-Mart, 564 U.S. at 349–50 (quotation omitted). Rather, the plaintiff must show that the claims “depend upon a common contention . . . that is central to the validity of each one of the claims in one stroke.” Id. at 350 (quotation omitted). “Commonality drives the initial Rule 23(a) inquiry,” In re Nissan N. Am., Inc., Litig., 122 F.4th 239, 246 (6th Cir. 2024), and over the last two to three years, the Sixth Circuit has expatiated on how district courts must perform a rigorous analysis of Rule 23(a)’s commonality requirement.

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Moore v. Westgate Resorts Ltd., L.P., (E.D. Tenn. 2025).

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Related

Singleton v. Wulff
428 U.S. 106 (Supreme Court, 1976)
Califano v. Yamasaki
442 U.S. 682 (Supreme Court, 1979)
Wal-Mart Stores, Inc. v. Dukes
131 S. Ct. 2541 (Supreme Court, 2011)
In Re American Medical Systems, Inc. Pfizer, Inc.
75 F.3d 1069 (Sixth Circuit, 1996)