18th Annual Workplace Class Action Report - 2022 Edition

478 Annual Workplace Class Action Litigation Report: 2022 Edition reasonable relationship to the City’s alleged security interest. Id . at *19. The Court agreed with Plaintiffs that permitting observant Muslim women to wear a hijab while being photographed as part of booking procedure would have reasonably accommodated their beliefs and also would be less burdensome on the NYPD. For these reasons, the Court denied Defendant’s motion to dismiss. Copeland, et al. v. Wabash County, 2021 U.S. Dist. LEXIS 88338 (N.D. Ind. May 10, 2021). Plaintiffs, a group of prison inmates, filed a class action against Defendants, Wabash County and the Wabash County Sheriff, alleging that their conditions of confinement resulting from the overcrowded and understaffed Wabash County Jail violated the Eighth and Fourteenth Amendments of the U.S. Constitution. Plaintiffs filed a motion for class certification pursuant to Rule 23, which the Court granted. Plaintiffs’ proposed class consisted of all persons currently confined, or who will be confined in the future, in the Wabash County Jail. Id . at *3. Plaintiffs asserted that the Jail’s chronic overcrowding led to many problems for the inmates, including an insufficient number of beds for all of the inmates, limited recreation opportunities, increased fighting among the inmates, the failure to either properly classify or separate the inmates by classification, insufficient monitoring by prison staff, and an inadequate amount of food. The Court found that at 91 current inmates, the numerosity requirement of Rule 23 was easily satisfied. As to commonality, the Court determined that Plaintiffs’ declarations filed in support of the motion for class certification indicated that the Jail was engaged in a practice of overcrowding, which led to numerous conditions of confinement causing inadequate and potentially dangerous living conditions for the inmates. Thus, the Court determined that Plaintiffs submitted sufficient evidence demonstrating the commonality requirement. Regarding typicality, the Court found that the inmates were all recipients of the same conduct or practice carried out by Defendants, and therefore Plaintiffs’ claims were typical to those of the class they sought to represent. For the adequacy requirement, Defendants did not contest that Plaintiffs were represented by experienced counsel, or that the named Plaintiffs would not vigorously pursue the class’ interests as well as their own. Therefore, the Court held that Plaintiffs meet the requirements of Rule 23(a)(4). For the Rule 23(b) predominance requirement, the Court ruled that liability would be based on a common question for all the proposed class members, and the resolution of each class member’s claim would hinge on the same operative facts relative to Defendants’ standardized conduct. Therefore, the Court determined that because a single injunction or declaratory judgment would provide relief to each member of the class, certification was appropriate under Rule 23(b)(2). For these reasons, the Court granted Plaintiffs’ motion for class certification. Dixon, et al. v. City Of St. Louis, 2021 U.S. Dist. LEXIS 27866 (E.D. Mo. Feb. 17, 2021). Plaintiffs, a group of detainees, filed a class action under 42 U.S.C. § 1983 and the Declaratory Judgment Act alleging violations of their equal protection and due process rights through Defendants’ policy of setting arbitrary monetary release conditions that exceeded an individual’s ability to pay and by detaining Plaintiffs solely on their inability to pay. Plaintiffs alleged that holding detainees in pretrial detention violated their substantive due process rights by failing to consider each detainee’s particular likelihood to appear and their threats of danger to the community and violated their procedural due process rights by detaining them for weeks before giving them a hearing or opportunity to challenge or modify their release conditions. Defendants filed a motion for judgment on the pleadings, and the Court denied the motion. Defendants contended that: (i) the Court lacked authority to compel the City Defendants to release state arrestees; (ii) the Court lacked jurisdiction to order the City Defendants to ignore bail orders issued by state judges; (iii) Plaintiffs’ claim was moot by virtue of Missouri Rule 33.01; and (iv) Plaintiffs lacked standing to seek an injunction against any future injury. The Court addressed the first two theories together and rejected the defense arguments because a lawsuit for injunctive or declaratory relief was cognizable against an official charged with enforcement of the challenged law. Moreover, the Court concluded that Plaintiffs’ claims against the City Defendants were not limited to the role of enforcing bail orders because Plaintiffs also directly implicated the City’s own conduct. Id. at *12. Accordingly, the Court ruled that Plaintiffs could maintain claims against the City Defendants. As to the City Defendants’ argument that the case was moot now that Missouri Rule 33.01 was in effect (which provided certain constitutional safeguards sought by Plaintiffs), the Court disagreed. It opined that voluntary cessation of a challenged practice did not necessarily moot a case where any Defendant could later resume the practice. Id. at *13. Finally, as to the City Defendant’s standing challenge regarding the sheriff’s deputies instructing arrestees not to speak at their bond hearings, the Court ruled that the sheriffs’ alleged practice was a factual question to be resolved on a full record and not by judgment on the pleadings. The Court also concluded that Plaintiffs sufficiently pleaded the existence of a widespread pattern. For these reasons, the Court denied City Defendants’ motion for judgment on the pleadings.