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Gang-Related News Articles
Welcome to the Gang-Related News Articles page. This page provides a list of articles pertaining to gangs and gang-related activities from various U.S. and Canadian news sources. A link to the source of each article is provided. The list of articles can be refined by date and limited to a specific state or Canadian province or territory using the control below.
2 arrested during Oxnard traffic stop, police say (Oxnard, CA): Oxnard police said they arrested two gang members Wednesday on suspicion of multiple felony violations.
Source: Ventura County Star Date: July 28, 2016
Shooting victim has gang ties (Walla Walla, WA): A 20-year-old male is being treated at Harborview Medical Center in Seattle after being shot multiple times at Paddock Elevators. Walla Walla County Sheriff John Turner confirmed the victim has gang ties, but that's all he could say as the investigation continues.
Source: My Columbia Basin Date: July 28, 2016
New initiative provides Paterson PD with $750K for anti-gang overtime costs (Paterson, NJ): In an effort to combat gang-related violence and crime, the Paterson police department has entered a new agreement with the State Police that will provide the city with $750,000 in federal funding, officials said.
Source: The Record Date: July 28, 2016
NYC Bloods gangster sentenced in Brunswick gun deal (Brunswick, GA): A federal judge sentenced a New York City gang leader to six years and eight months in prison last week, stemming from his arrest last October in a drugs-for-guns deal in a Brunswick motel.
Source: The Brunswick News Date: July 27, 2016
Gang shooting critically wounds man (Walla Walla, WA): Walla Walla County Sheriff John Turner says a shooting victim called 911 to report his injuries at about 7:05 p.m. Tuesday. Upon arrival at Paddock and Harvey Shaw roads, deputies found a 20-year-old man who had been shot multiple times. No one else was at the scene.
Source: My Columbia Basin Date: July 27, 2016
16 suspects facing federal charges in connection with Pueblo crimes (Pueblo, CO): Sixteen people are facing federal charges in connection with crimes committed in Pueblo. Local authorities are partnering with federal agencies to disrupt gang activity, violent crime, and narcotics distribution in the city.
Source: KXRM FOX 21 News Date: July 27, 2016
Men tied to Selma killing surrender as agencies continue gang crackdown (Selma, AL): Two suspects wanted in connection with a deadly shooting in Selma are behind bars. When authorities turned up the heat in the search for the duo, they decided to surrender Wednesday. Joe Jackson, 20, is charged with capital murder.
Source: WTVM 9 News Date: July 27, 2016
Evansville Man Dies In Gang-Related Shooting (Evansville, IN): The Vanderburgh County Coroner says 20-year-old Michael Farmer was murdered near downtown Evansville early Wednesday morning. And officers say, the murder is gang-related.
Source: 44News Date: July 27, 2016
FMPD: Club Blu shooting possibly gang-related (Lee County, FL): NBC2 spoke with Fort Myers interim police chief Dennis Eads Wednesday about the latest on the Club Blu shooting investigation. Chief Eads confirmed the two victims were just innocent bystanders, likely caught in the middle of gang violence. He is not calling this a gang-related shooting, but said there were several names on the list of suspects he knows have gang affiliations.
Source: WBBH NBC2 News Date: July 27, 2016
Woman Shot In South Chicago An Innocent Victim Of Gang Feud, Neighbors Say (Chicago, IL): The neighbors who lived on a South Chicago block where young mother was shot and killed shortly after moving to the area Tuesday believe her death was the result of an ongoing gang conflict.
Source: DNAinfo Date: July 27, 2016
Silva Trial: Prosecutors lay groundwork for jury on gang culture (Greeley, CO): In the first full day of witness testimony in the three-week trial of Greeley gang member John Anthony Silva, prosecutors worked to expose the tangled network of gang activity connecting three crimes between 1998 and 2013.
Source: Greeley Tribune Date: July 27, 2016
Loudoun deputies investigating gang-related, underage prostitution ring (Loudoun County, VA): The Loudoun County Sheriff's Office's Tactical Enforcement Unit is investigating an underage prostitution ring spanning Virginia, Maryland and D.C. ran by MS-13 members for the profit of the gang's leadership in El Salvador.
Source: Loudoun Times-Mirror Date: July 26, 2016
Regina gang member killed drunk man because he was wearing a red shirt, court hears (Regina, SK): Joshua Michael Harden was wearing a red shirt and hat when, while looking for his girlfriend, he wandered into a house party on Garnet Street. The colour of his clothing became the motive for a violent attack that left him dead. "This incident involved a level of violence resulting in death, between persons not known to each other, in a culture of street gang violence — a situation all too common in the city of Regina which has left numerous families both heartbroken and devastated," Crown prosecutor Sonya Guiboche said Tuesday.
Source: Canoe News Date: July 26, 2016
El Cajon Gang Member Caught Selling Meth to Informant Gets Life in Prison (San Diego, CA): A 53-year-old West Coast Crips gang member from El Cajon was sentenced Tuesday morning in San Diego federal court to life in prison for multiple drug-related crimes.
Source: Santee Patch Date: July 26, 2016
Three-week trial begins for longtime Greeley gang member charged with organized crime (Greeley, CO): In what has become a sweeping organized crime case, John Anthony Silva's day in court began at 4:15 Tuesday afternoon after almost two days of jury selection. Silva has been charged with an array of offenses including drug charges, assault with a deadly weapon, burglary, robbery and intimidation of a witness, all spanning two decades. His jury trial will last the next three weeks.
Source: Greeley Tribune Date: July 26, 2016
Gang member kept from 'Street' activity (Portsmouth, OH): The conviction of a Columbus gang member in one of the highest profile cases in several years has been upheld by the Court of Appeals. Thomas O. Smith, 27, of Columbus, an alleged member of the 22nd Street Bloods, was convicted by a Scioto County Common Pleas jury after a four-day trial held in February 2015 for his participation in a heroin trafficking operation, which involved smuggling heroin and cocaine from Columbus to Portsmouth.
Source: Portsmouth Daily Times Date: July 26, 2016
Social media leads to arrest of suspected gang member in Rochelle Park (Passaic, NJ): Passaic police say they used Facebook to track a reputed gang member wanted for a stabbing that occurred four years ago, which led to an arrest on Monday in Rochelle Park.
Source: The Record Date: July 26, 2016
Pueblo gangs quieter this summer, but still active (Pueblo, CO): Pueblo's gangs have not been in the news much this summer compared to last year, but police say they are still out there and they are still committing crimes. Last summer, the streets of Pueblo were filled with gunshots, sending dozens of people to hospitals. Some of the victims died. It seems quieter in 2016, but that is because police are going after the leaders of the local gangs.
Source: KOAA 5 News Date: July 26, 2016
U.S. Attorneys in Illinois, Indiana File Charges Against Latin Kings (Chicago, IL): More than 40 high-ranking members of the Latin Kings street gang have been charged for violent racketeering, selling drugs and attempted murder as part of a sweeping, federal investigation into the operation in Illinois and Indiana, law enforcement officials announced Tuesday.
Source: The Wall Street Journal Date: July 26, 2016
Two gang members sentenced to 25 years to life for fatal shooting of rival on Coney Island street (Brooklyn, NY): Brooklyn District Attorney Ken Thompson on Tuesday announced that two gang members were sentenced to 25 years to life in prison following their murder conviction in connection with the death of a rival. They lured the victim out of a store then ran up behind him and shot multiple times.
Source: Brooklyn Daily Eagle Date: July 26, 2016
Disclaimer: The news items and links are provided as an informational resource to you. Each of the linked Web page providers has its own policies and practices regarding how long a link to its news item is available before it is archived or a fee is charged. Also, some of the sites require users to register in order to access materials. We do not guarantee the accuracy, currency, content, or quality of any linked Web site information, nor whether a link from the Web site may take the user to unintended or objectionable content. Please contact us to report any problems. Thank you.


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Setup was simple, works great. I like it when plugins just "work."
Hi, thanks for this plugin. It's really cool plugin, i want to add auto number and also add date (must show today)
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subset: commoncrawl


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Living in a shore town is proving to be quite a sartorial challenge so far. The weather can be so different here compared to my parents' house or my office. There's even a big difference between the coastline and my apartment four blocks inland! Once summer hits, it's just going to be hot all the time, and getting dressed will involve throwing a dress over a bathing suit. Since it's still spring and the temperature keeps fluctuating, I've developed a system to stay comfortable throughout the day with some transitional spring essentials.
Today I'm partnering with Betabrand to talk about these spring essentials. Betabrand is a company whose focus is on versatile and comfy clothes that make a statement both in the office and on the streets.
Admittedly, it's nothing truly groundbreaking, but my daily wardrobe (at least during the work-week) consists of a short-sleeve or 3/4-sleeve dress with leggings and moccasins. I also have a hooded sweater with pockets and a long shawl/scarf that I wear for the cooler mornings. By midday, if it starts to warm up, I can lose the leggings and sweater. If it starts to get windy or rainy, I can wrap the scarf around me like a shawl. Most of my pieces are neutral or similarly colored, so mixing and matching is easy and getting dressed in the morning is quick and painless.
Betabrand offers a line of women's pants that are great transitional pieces. Their office yoga pants are dressy enough to wear to the office, casual enough to wear out after work, and fall into my favorite category of clothing, "feels like pajamas/looks like a million bucks"! So great for making the transition between seasons!
Spring Essentials with Betabrand.
Living in a shore town is proving to be quite a sartorial challenge so far. The weather can be so different here compared to my parents' house or my office. There's even a big difference between the coastline and my apartment four blocks inland! Once summer hits, it's just going to be hot all the time, and getting dressed will involve throwing a dress over a bathing suit. Since it's still spring and the temperature keeps fluctuating, I've developed a system to stay comfortable throughout the day with some transitional spring essentials.
WEARING • Day and Night with Tobi!
It's always fun to step out of your comfort zone when it comes to fashion. Rompers and cocktail dresses aren't frequently a part of my wardrobe. I'm so grateful that the kind folks at Tobi.com recently reached out to me to review some of their products, because these two pieces will be in heavy rotation all through spring and summer. I think the next stop on the Comfort Zone Train is probably bodysuits, but let's talk about these day and night looks. The romper is blousy and comfortable and perfect for drinking beers on the beach. I paired it with sandals and a cool pin from a local AP shop. The dress is so unique, I decided to keep it simple with my favorite black velvet wedges and a little jewelry. It will be perfect for a night of dancing at Porta or Paradise (or both)! IMPORTANT: new customers at Tobi get 50% off their first order! Click over to shop dresses, jumpsuits, crop tops, and more!
romper: Jenalai Blousy Romper c/o Tobi - tank: J. Crew via Goodwill - sandals: Target - shades: Topshop
shawl: vintage via Goodwill - earrings: vintage from my grandma - pin: Red Moon (Asbury Park!) - bag: Madewell
dress: See Me Now Mesh Shift Dress c/o Tobi - shoes: Urban Outfitters - earrings: vintage from my grandma - glasses: c/o Firmoo
Photos by the amazing Diana Van Horn Photography!
Disclaimer: Product provided by Tobi, but all opinions are my own. Thank you for supporting those who support this blog. :)
REVIEW: Runyon Canyon in YogaOutlet.com!
One of my favorite memories from my recent trip to LA was one of the first. As soon as I arrived at my friends' apartment, we decided to take a hike in Runyon Canyon. Now if you know me at all, you know I don't like exercising. I figured, "When in Rome," ya know? This was around 2PM PST when I'd been awake since 4AM EST without eating any food, so it maybe wasn't the wisest choice, but I regret nothing. The views were truly extraordinary, even on a smoggy, hazy LA afternoon. It felt good to get the ole heart pumping, even though at times I thought it was going to come out of my chest like The Chestburster. I was delighted that my new leggings from YogaOutlet were delivered right before I left (and that I decided to pack them) because they were perfect for the hike.
I chose the Teeki New Moon Black Hot Pants to review because I have a thing for the phases of the moon. The day of the hike, I paired the leggings with my pizza-phases-of-the-moon tank, because why not? Since returning from LA, I've worn the leggings to practice yoga a few times, and I even wore them to work under a dress (and got lots of compliments, by the way). A very versatile piece, for sure.
Disclaimer: Product provided by YogaOutlet.com , but all opinions are my own. Thank you for supporting those who support this blog. :)
Off to LA + a Sale! 🌴
Greetings from 32,000 ft in the air! I'm currently somewhere over the Midwest? I can see the Rocky Mountains way in the distance? I used to know geography? Why isn't the map on my screen working, United?
I'm spending my flight slowly starving to death (One little wafer cookie, United? Throw a bitch a bagel!) and watching free movies (For real thanks, United!) Maybe I cried watching "The Force Awakens" and maybe I cried watching "Spotlight" — what about it?
Anyway, I'm off to LA for about a week to spend time with some dear friends and work on my tan. 😎 If you have any suggestions of things I must see or do out here, please let me know. Also follow along on Instagram or Snapchat (laurenwilkey) to join in on the fun.
One last thing, everything in the shop is on sale while I'm away. All vintage is 45% off + you can use code LAWOMAN for an additional 15% off!
A Wild Tonic Vintage • Shop Preview 2/6/16.
At long last, new vintage is heading into the shop. Happy Saturday, friends! :)
My Vintage Valentine.
Some pretty pinks and reds to help get into the Valentine's Day spirit. 1 • 2 • 3 • 4 • 5 • 6 • 7 • 8 • 9 • 10 ♥
Winter Storm Jonas 2016.
Well, we finally got the snow I've been waiting for! About 20" fell on Asbury Park last weekend, and I was holed up on my friends' couch seven blocks from my apartment. We snacked, drank, napped. I watched "The Martian" and "The Revenant" and did some spreadsheeting™ for my job like a real nerd. Lots of shore towns experienced heavy flooding, but AP fortunately was spared. Diana and I took a trek out into the storm one night. The snow was up to our knees, the wind was wild, and we stayed out there for maybe ten minutes at the most. Sunday morning, we went down to the beach. The waves were insane and there was snow on the sand, which I've never seen before!
P.S. The "Let it Go" coloring book giveaway winner has been announced. Click over to see if you're the lucky winner! :)
CLOSED | REVIEW + GIVEAWAY: "Let It Go! Coloring and Activities to Awaken Your Mind and Relieve Stress"
I know everyone always says it, but this is the first year that the holidays felt truly ~stressful~ for me. As an "adult" this year (no longer a "kid" when you're pushing 30, but still have to sit at the kid's table), I had many presents to buy. This is my first year living on my own away from my parents' house, so a lot of traveling had to be done. Worst of all, I had to work on Christmas Eve morning, and Christmas Eve is our big day. I actually found myself quoting Brand New every day in December, at least twice daily: Is this the way a toy feels when its batteries run dry? Blah blah blah, everyone is stressed at the end of year, right? Well, this review couldn't have come at a better time.
By now, I'm sure you've heard of, or perhaps even tried your hand at adult coloring. When I was in Belfast, a few of my friends had these lovely coloring books and markers on their coffee table. They told me that they would come home after a long, stressful day at work, drink some tea, and color while they watched television. I was intrigued, but not 100% sold on the idea. When I was a kid, coloring wasn't a fun activity. As a typical type-a/big sister/Virgo, I was a total perfectionist. Ask my mom! If a single bit of color went outside of the lines, it was ruined. Tears were shed and the page was ripped out. God help us if it was a good page, like Belle in her yellow dress or Ariel on the rock with the waves splashing up around her.
While I have lightened up significantly in my old age, I still didn't think adult coloring was for me. I saw lots of friends on Instagram posting photos of their work, always double-tapping with a tinge of jealously. When the kind folks at Juan Derful, Ink recently reached out to me to do a review of their coloring book, I thought it was the perfect opportunity.
The book is called "Let It Go! Coloring and Activities to Awaken Your Mind and Relieve Stress", illustrated by Sherise Seven, and it's full of finely detailed art, inspirational words, and stress-relieving activities. Perfect for adults and teens, the book combines self-help and creativity in the best way. No longer was I worried about making sure the colors I used were true-to-life, nor did I worry if I colored outside of the lines! I recently spent an evening coloring while watching "Making a Murderer" (if anyone wants to talk theories, hit me up!) and it truly helped with the stress, which I think is very telling. ;)
Also, how great is the color protector page, specifically designed so your colors don't bleed? Brilliant!
A Wild Tonic readers can use code "WILDTONIC" for 10% off of the book from now until January 31st!
Now, onto the giveaway...
One copy of "Let It Go! Coloring and Activities to Awaken Your Mind and Relieve Stress"
Watch the Video Flip Through above and leave a comment with your favorite page in the book.
And for a bonus entry, follow A Wild Tonic on Bloglovin (and leave a second comment).
Don't forget to leave a way to contact you in your comment, in case you're the lucky winner.
The giveaway is open worldwide, and the winner will be randomly chosen and announced on 1/20 at 9PM. Good luck! :)
P.S. The Firmoo giveaway winner has been announced. Click over to see if you're the lucky winner! :)
Disclaimer: Product provided by Juan Derful, Ink, but all opinions are my own. Thank you for supporting those who support this blog. :)


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Discounted FINAL SALE ITEM
Small, Medium, Large, X Large sizing
Medium fit most women & large fit most men
Webbed gloves with embossed neoprene ridges for added hydro resistance.
Durable flexible neoprene construction for maximum comfort and movement.
New 3D mesh promotes accelerated drying time.
Open finger and thumb give you the feel in the water as you train.
Adjustable for a secure, custom fit.
May be utilized throughout a class ( easier to hold noodle with this style of mitt)
Helps to secure proper posture & better balance
You may slice, fist or web mitt for increased upper body resistance and strengthening
Color: Yellow (Instructor may easily to see clients hand positions in water)
There is no further discount on Final Sale items.
However, you may join our WaterART Professionals Club and save 20-25% on other products as well as earn a free gift.
If you are already logged on - as a WP member your discount is automated with all entries into your shopping cart. Your invoice will itemize the savings!


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A very useful plugin!! With this WP become a more complete CMS!!!
Very useful, clean and well documented !
Thanks to Scribu for this nice solution.
I just registered with wordpress.org simply in order to review this plugin.
I'm a seasoned programmer who's done a number of sites in WordPress, but only recently have I been attempting to use WordPress for more complicated functionality.
I spent the past two weeks trying to come up with a solution for my current project. I tried a number of hacks, from putting a bunch of encoded information in taxonomy descriptions to using my own separate database table. I was about to call it quits and build everything from the ground-up using a PHP framework.
Yesterday I discovered Posts 2 Posts. if I had only known about this plugin sooner!
Having the power to define relationships between custom post types makes so many things possible.
For instance, a recipe site:
1. Simply create a custom post type called "Ingredient". (It's very easy to write your own code to do this, but numerous plugins are also available.) An example post could be "San Marzano Tomatoes" with a description of this type of tomato, images, comments, etc.
2. Create a custom post type called "Recipe".
3. Using Posts 2 Posts create a connection between Recipe and Ingredient. The connection can define custom fields such as "Amount".
4. Create templates for viewing your custom post types, including Posts 2 Posts code for viewing the Ingredients in a Recipe, or for viewing all Recipes that include the given Ingredient.
Finished! You've just made a very powerful recipe site. Now when you create a new recipe you can easily select ingredients from handy drop-down menus in the admin screen. You can also associate each ingredient with custom fields like "amount". You can find recipes by searching for certain ingredients.
The concepts behind Posts to Posts is so powerful you'll be wondering why it hasn't already been included into the WP core..
Thanks so much to the creators of this plugin.
I just don't know how I could cope without this plugin. Websites are, by the designer of the internet, a collection of interconnected things.
Being able to define and configure the relationships using WordPress hooks means that I can easily create many copies of any system without hours of manual editing. I don't even have to log in to do anything.
Took me about 5 minutes to learn how to use and easily saved me 10 hours of custom coding on the first project alone.
Nice Work!
Full of options.
Just perfect for theme developers !
Finally a plugin well written and really, really, really useful.
You need to write at least a little bit php. This isn't a plugin which does all the work for you, but it does what it should be and this is extremly useful.
Posts To Posts is easily in my top five best plugins, if it's not my number one. It's extremely flexible and easy to setup, follows all WordPress best practices, works like a charm and has a number of features out of the box.
You must log in to submit a review. You can also log in or register using the form near the top of this page.


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Tuscaloosa County takes down Bessemer
Published: Tuesday, September 27, 2011 at 3:30 a.m.
Last Modified: Monday, September 26, 2011 at 10:21 p.m.
BESSEMER | The Tuscaloosa County Lady Wildcats won a four-game match against Bessemer City to run their record to 8-16 overall, 3-3 in Class 6A, Area 9.
TCHS won by scores of 25-12, 25-13, 23-25 and 25-17.
Alex Smith had 11 kills and seven digs for TCHS. Jaymie Herndon had 24 assists and four aces. Jamie Robertson had five kills, five aces, three digs and two blocks. Nicole Miller posted five aces, four kills and four blocks. Lauren Sevenish had 14 assists.
TCHS plays at home against Holy Spirit at 6 p.m. on Thursday.
Reader comments posted to this article may be published in our print edition. All rights reserved. This copyrighted material may not be re-published without permission. Links are encouraged.


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Frederik & Mary's Dannebrog Tour – Day One
Yesterday, Crown Prince Frederik and Crown Princess Mary began their five-day tour aboard the royal yacht, the Dannebrog. They will visit the Danish cities of Skagen, Hanstholm, Hirtshals and Aarhus. The visit to Skagen began with the arrival of the Dannebrog at the Old Pier in the Port of Skagen, where Frederik and Mary appeared on the deck of the yacht with their youngest children, seven-month-old Prince Vincent and Princess … Continue reading


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A British charity supported by Hollywood actress Scarlett Johansson says it objects to her new role as a spokesperson for the Israeli firm SodaStream.
Oxfam says it is concerned because the SodaStream factory operates in the West Bank.
Ms Johansson has been an ambassador for the charity since 2007.
Britain called in Israel's envoy last week to protest against Jerusalem's intention to build more settlements in the West Bank. In stark contrast, Australia's Foreign Minister, Julie Bishop, in Israel last week for Ariel Sharon's funeral, urged the international community to refrain from branding the settlements "illegal".
Australian Foreign Minister Julie Bishop made waves during a visit to Israel this week.
She told the Times of Israel that, in her view, the settlements may not be illegal under international law and that the world should refrain from making that argument while the peace process is under way.
Dr Alexander Yakobson teaches ancient history at the Hebrew University, Jerusalem. His specialities are democracy, politics and electioneering in the late Roman Republic. In common with other Israeli academics on the left he has, however, sought to broaden his areas of specialism in the light of contemporary peace-making (so-called) in the Middle East.
The EU has hit out at Israel after a Jerusalem official said that tenders for new settlements would be announced following the release of Palestinian prisoners on Sunday.
An EU diplomat told Israel's Channel 10 news that Jerusalem should expect a "harsh response by the European governments if it intends to go in this direction".
The Co-operative movement has confirmed there are no plans to alter its policy of boycotting companies which source produce from Israeli settlements in the West Bank.
A government programme to promote Jewish settlement in the Galilee has raised objections from Arab-Israeli politicians and environmentalists.
Prime Minister Benjamin Netanyahu was forced this week to freeze plans to construct 24,000 new homes in the West Bank following American and Palestinian protests over the move.
The Housing Ministry, headed by Minister Uri Ariel from the Jewish Home party, had been on the point of publishing tenders for several building projects in the settlements.
Britain's new Middle East Minister has used his first visit to Israel to criticise settlement building and warn that it could hamper peace efforts.
Hugh Robertson said settlement announcements "erode public support" in Britain, and warned that building could "endanger the viability of a two-state solution and peace process".
International literary stars have signed an Israeli-led campaign to condemn the destruction of Palestinian villages in the southern Hebron hills.
The campaign was initiated by Israeli author David Grossman last June and has been backed by Nobel laureates, poets and playwrights around the world.


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The newest exhibit to hit the Indiana State Museum will have kids and adults doing backflips - er, I mean kickflips! Rad Science: Skatepark Physics rolled in to the museum last week and continues through January 3, 2016. Jump into the physics ... [ Read More ]
Rad Science Skatepark Physics at the Indiana State Museum | GIVEAWAY
This post may contain affiliate links. See my disclosure policy for details.


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jobs near Sugar Land, TX
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Sales Manager
Classic Soft Trim - Houston, TX
Responsibilities include telemarketing, sales calls and identifying and procuring sales leads that convert into profitable customers....
Local Delivery Driver
Snider Fleet Solutions - Houston, TX
Valid driver's license and good driving record is required. Required license or certification:. Valid driver's license. Box Truck Driving:....
Genius - Technical Customer Service (US)
Apple - Houston, TX
You also educate your team members about products, while independently keeping your own technical know-how up to date....
Field Service Technician - Commercial Food/Retail Equipment
KASCO Corporation - Houston, TX
Valid, clear driver's license in the state he/she resides. Maximize sales dollars of KASCO services customer calls by delivering/sale of KASCO products and full...
Real Estate Agent Recruiter
NRT LLC - Houston, TX
Ability to make at least 30 cold calls a day. NRT LLC is the nation's largest owner and operator of residential real estate brokerages operating in more than 50...
Service Specialist - Retail Customer Service (US)
Apple - Houston, TX
Whether you're helping customers get started with the Mac or finding answers to their questions about other Apple devices, you're ready to share knowledge and...
SSAS Consultant - TX
DB Healthcare, Inc. - Houston, TX
Collaborate with client subject matter experts to define functional and technical requirements specifications....
Entry Level Sales Representative
Power Home Remodeling - Sugar Land, TX
When you work at a company where the CEO started at entry level less than a decade ago and worked his way to the top, you know we mean it when we say we're...
Uber Driver Partner (Choose Your Own Hours)
Uber Partner Drivers - Houston, TX
Class b driver, local truck driver, company truck driver, taxi driver,. Driver, heavy and tractor-trailer driver, cdl truck driver, class a or....
Business Development Manager
OfficeMax - Houston, TX
All qualified applicants will receive consideration for employment without regard to race, color, religion, sex, national origin, citizenship status, marital...


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Feeling perpetually dissatisfied with your current circumstances may indicate a deeper problem. When we forfeit our agendas, God helps us discover His purposes and joy.
READ: Ps. 46:10; Prov. 19:23; Eccl. 2:22-26; 1 Tim. 6:6-12; James 3:14-16; James 4:1-10.
HEART ISSUE: Where are you feeling discontent, stuck or frustrated? What is inhibiting you from receiving God's plan?
PRAYER FOCUS: Father, thank You for Your merciful counsel. Show me what is keeping me from savoring each moment. Help me enjoy the life You've given me. Amen.
Draw closer to God. Experience the presence of the Holy Spirit every month as you read Charisma magazine. Sign up now to get Charisma for as low as $1 per issue.
Dare to go deeper in your faith. Our "Life in the Spirit" devotional takes you on a journey to explore who the Holy Spirit is, how to interact with Him, and how He works in your life. Are you ready to go deeper?


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- Miss Florida 2017 stripped of crown days after win - US Weekly
- Lindsay Lohan steps out amid relationship drama - TMZ
- Was Taylor Swift snubbed by the VMAs? - Gossip Cop
- Rachel Platten sings "Fight Song" with lots of stars - Just Jared Jr
- Farrah Abraham sizzles in a revealing bikini - Radar
- New pics from the Clooneys' Italian summer - Lainey Gossip
- Fox News snubs major DNC moment - The Hollywood Reporter
27 March 2009 at 7:08 AM
Jessica Alba Gets GLAAD
Posted in Jessica Alba Gets GLAAD
About this photo set: Jessica Alba and husband Cash Warren attend the annual dance at the American Museum of Natural History in New York City on Thursday evening (March 26). The 27-year-old… Read More Here
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Written on: 25/03/2013
Ordered a game over a week ago and they CLAIMED they dispatched it the day after but there's still no sign of it.
Absolutely terrible. AVOID AT ALL COSTS
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Senators prediction panel: Game 30The Ottawa Senators take on the Vancouver Canucks at Scotiabank Place. Which team will come out on top? Our prediction panel weighs in.
Senators reveal more details of all-star game extravangazaThe first time the Stanley Cup made an appearance in the Rideau Canal, 106 years ago, it was drop-kicked into the water by a member of the Ottawa Silver Seven ...
Carkner focused on returning, not fighting history with BoogaardMatt Carkner says it will be business as usual when he returns to National Hockey League game action Saturday against the Vancouver Canucks.
Young and old share the blame for SenatorsIt's too easy to dismiss the Ottawa Senators string of third period collapses as simply the product of youth. At least coach Paul MacLean isn't buying that.
Poster pages contest: Dec. 9 code wordGet today's word here.
Senators blow yet another lead in loss to DevilsIf you haven't heard it before, here it is again: don't ever, ever, turn off the TV or leave the building early when the Ottawa Senators are playing.
Senators notebook: Carkner could return SaturdayRegardless of how much Ottawa Senators coach Paul MacLean chooses to use Matt Carkner when he returns to the lineup – most likely Saturday against the Vancouver Canucks – it ...
Auld gets a rare start in New JerseyAlex Auld will start in goal for the first time since Nov. 20 tonight as the Ottawa Senators hope to rebound following Wednesday's 5-3 loss to the Washington Capitals.
Video: Did Ovechkin spear Neil on purpose?Watch the video and let us know what you think.
Ovechkin escapes punishment for spearing NeilAlex Ovechkin has escaped punishment for spearing Chris Neil on Wednesday
Local News
Local Arts
What to do this weekend: Ribfest and Buskerfest colliding is ...
Local Arts
The buskers are back in town
Science of Summer: A desert where sand stays cool
Test your Tragically Hip knowledge with this quiz
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Anna Soo
United States
No Biography provided
United States
No Biography provided
Sara Faatz
Developer Media
United States
With some 20 years of experience leading corporate marketing and community building for multimillion-dollar international organizations, Sara is a dynamic leader with outstanding interpersonal skills. A respected influencer within the industries she contributes, she has a proven track record of conceptualizing and orchestrating campaigns that evolve the brand and positively impact the company's image and revenue.
Over the years, she has run marketing departments (both large and small), built community programs from the ground up, created partner programs, and acted as a brand ambassador and spokesperson for various organizations.
Currently, Sara is leveraging her experience in the developer marketing space to help her clients achieve and exceed their goals through partnership with Developer Media.
Sara was recently interviewed by Locassa as part of the Expert Interview program. You can read what she had to say about marketing to developers and the current state of the industry here.


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Free personalized radio that
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Stare And Stare (Live)
Features of This Trackfunk roots
chromatic harmonic structure
intricate melodic phrasing
mixed minor & major key tonality
thru composed melodic style
use of the wah wah pedal
a dynamic male vocalist
prominent percussion
political lyrics
These are just a few of the hundreds of attributes cataloged for this track by the Music Genome Project.show more
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In Stock & Ready To Shipin_stock
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Vintage overdrive-soaked sounds for the stage and studio.
The Marshall 1974X 18W 1x12 Combo Amp is a handwired reissue of the model 1974, a combo originally produced from 1965 to 1968. Introduced as a practice combo amp in 1965, it wasn't as loud as the terror-inducing heads Marshall was producing, but it could rock, giving up incredible lead and crunch sounds at low volumes. The 1974X combo comes with 2 EL84 tubes in the power amp, 3 ECC83s in the preamp, an EZ81 rectifier tube, and features valve-driven tremolo. A proprietary, aged reissue of the 20W, ceramic magnet Celestion T1221 speaker used in the original adds to the Marshall 1974X's tonal authenticity. Marshall includes a footswitch with your 1974X Combo Amp.


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According to the Seattle Times, Bellevue football coach Butch Goncharoff will be fired.
You can read more here.
According to the Seattle Times, Bellevue football coach Butch Goncharoff will be fired.
You can read more here.
Kingston athletic director Jared Terrible said Thursday that the school has named Alec Grimm as the new football coach.
Grimm accepted the school's offer to coach the Buccaneers on Wednesday, Terrible said. He'll replace former coach W. Todd Harder, who resigned after four seasons.
Alec Grimm, a 2011 Bainbridge High graduate, is the son of former Bainbridge football coach Andy Grimm, who coached the Spartans for 18 seasons before leaving his post last fall.
It's an interesting hire considering former Kingston assistant coach Jeff Rouser is replacing Andy Grimm at Bainbridge.
It wouldn't be surprising to see Harder join Rouser's staff at Bainbridge or see Andy Grimm join his son's staff at Kingston.
Phil Pugh is returning as football coach at North Mason High School.
It'll be the third stint as coach and he'll be coaching at the stadium named after him.
He's a member of the Washington State Football Coaches Association Hall of Fame and Kitsap Sports Hall of Fame.
Pugh was 162-107 in 27 years at North Mason and he led the Bulldogs to the Class A state title in 1982. He coached from 1974 to 1994 before retiring. He returned and coached from 2004-09.
Pugh's replacement, Jeff Bevers, stepped down following the season after six years and a 22-38 record. Bevers is the track and field coach at North Mason.
Once high school football teams start playing games, they'll be limited to just two contact days per week.
Typically two days of practice is normal for a high school team. Mondays tend to be a lighter practice. There's contact Tuesdays and Wednesdays. Thursdays are a lighter practice (often a walk through) as teams get ready for Friday games.
Here's a list of amendments (rules) the WIAA representative assembly passed this year.
Another notable change makes singlets optional in wrestling.
Here's the WIAA's release on the changes:
RENTON, Wash. – The Washington Interscholastic Activities Association (WIAA) Representative Assembly voted to pass six amendments (rule changes) for the 2016-17 school year, the Association announced Monday.
Four passed amendments affect both middle level and high school programs. The first will limit each football team to two contact practices per week following their first contest. After a team's first jamboree or game, they will be allowed no more than two thud or live action drills for that week, excluding their next contest. Thud is defined as drills that run at an assigned speed through the moment of contact; no pre-determined "winner." In addition, contact remains above the waist, players stay on their feet and a quick whistle ends the drill. Live action is defined as game-like conditions where players may be taken to the ground.
"With the annual education programs for coaches, parents and athletes, Washington has remained at the forefront of player safety in football starting with the passing of the Lystedt Law in 2009," WIAA Executive Director Mike Colbrese said. "This step goes beyond education and will provide additional protection for our student-athletes."
In wrestling, student-athletes will have the choice to continue wearing a traditional one-piece singlet or have the option to compete in a two-piece outfit consisting of close-fitting shorts and a short-sleeved compression top.
The third middle level and high school amendment requires member schools to be compliant with WIAA rules. Schools will also be expected to comply with WIAA fact-findings and willingly provide requested information.
The final middle level and high school amendment focuses on the participation of eighth graders. For the 2016-2020 classification cycle, schools with an enrollment of 104 or less may use eighth graders for their athletic and activity programs. The enrollment number was determined by less than one-half of the largest 2B school enrollment.
Two middle level-only passed amendments center around the participation of fifth and sixth graders. In all athletics except football, schools may use sixth graders to participate if they have an enrollment of 60 students or less students. Fifth and sixth graders may be used if they have an enrollment of 40 students or less.
In addition to the passed amendments, the Representative Assembly also approved three Executive Board members. Pat McCarthy of the Seattle School District, Lory Wyborney of Rogers (Spokane) High School and Ken Lindgren of Oakesdale High School will remain Executive Board Members representing Districts 2, 8, and 9, respectively.
The Representative Assembly is comprised of 53 (35 high school, 18 middle school) school administrators from each of the nine WIAA districts. For an amendment to pass, 60 percent approval is needed from the voting members of the Assembly.
For more information about the passed amendments, please visit the WIAA website.
They were showing it off on Twitter tonight:
The report on the WIAA's investigation on the Bellevue football
program and be seen here.
The Seattle Times breaks it down here.
As soon as North Kitsap linebacker Bob Evans learned Linfield University was interested in him, he knew where he wanted to go to that school.
Linfield has a special place in his heart. His uncle, Tony, played there. He was a freshman on the national championship team in 1984 before his career was cut short because of injury. His family is from the McMinnville, Oregon, area.
Linfield expressed interest in January. It took a few months between financial aid and other reasons before all the pieces fell into place, but he committed to the Wildcats a few weeks ago.
"It hasn't really set in," Evans said. "I'm super excited. I still can't get over the fact that I'm going to that school with such a great football program and that history."
Linfield is an NCAA Division III power that dominates the Northwest League. The program has won four national championships in football.
Evans was a three-year starter at linebacker for the Vikings. As a junior and senior he was named Olympic League 2A defensive MVP and Associated Press All-State football second team.
He's been told he'll stay at linebacker, either middle or possibly outside backer.
The Washington Interscholastic Activities Association completed its fact-finding investigation regarding the Bellevue High School football program on Thursday and presented it to the school district.
Here is the press release in it's entirety;
Fact-Finding Report for Bellevue High School Complete
RENTON – The results of an independent fact-finding of alleged violations toward the Bellevue High School football program are complete. The fact-finding report has been presented to the Bellevue School District for them to review.
The fact-finding examined five specific allegations as requested by the Bellevue School District in August 2015.
The results of the independent fact-finding of the alleged violations include facts regarding four of the five allegations that:
fact-finding concluded that there was not sufficient information to
support the fifth allegation that athletes received subsidized
housing to gain eligibility. The report also details
additional areas of concern that arose during the course of the
The Bellevue School District is committed to a thorough review and a timely response to all information included in the fact-finding report. Per WIAA process, Bellevue High School will report on the findings to the KingCo League.
"Our mission is to ensure that all students in the state are competing on a fair and level playing field," said WIAA Executive Director Mike Colbrese. "The Association provides structure and process for schools and districts to ensure there is accountability."
Due to the ongoing process of review, the WIAA and the Bellevue School District will not provide additional comments or statements at this time.
Kingston senior Alex Barrett is helping the Buccaneers' undefeated soccer team while eagerly awaiting his football career on the next level.
Barrett, who scored two goals for Kingston in Tuesday's Olympic League 2A showdown at Port Angeles, recently committed to play football at Ohio Wesleyan, a NCAA Division III school in Delaware, Ohio.
"I'm excited," said Barrett, who rushed for 459 yards and six touchdowns for Kingston's football team in the fall.
The 6-foot-1, 220-pound Barrett expects to play running back at the next level.
Here's the release from the school:
We are pleased to announce the hiring of Paul Theriault as the Bremerton Head Football Coach and substitute on contract. Paul comes to us from Colusa, California where he has held the position of PE teacher and Head Football Coach since 2012. In 2013 he was named "Mid-Valley Coach of the Year."
He is known for his organizing and fundraising for his team's community based projects and team activities.
There will be a meet-and-greet on Friday, April 15th at 6:00 pm at Bremerton High School.


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Big nice gelding for sale, 15'3" maybe 16 now haven't measured him in a while. Loads, clips, been shown in 4-H, trained and rode by my daughter. He would…$3,500
Mocha is an amazing 16hh 7yr old mare with beautiful gaits and an incredible disposition. She has done courses up to 3' and single fences up to 3'6" with…$8,500
Allie is 1/2 welsh pony 1/2 thoroughbred for sale or for lease. I have been with her the past four years, but attending college has prevented me from giving…$1,500
DM Geronimo's Red Fox Red Roan Colt Blu Geronimo Hancock x SF Skippa Doll http://www.allbreedpedigree.com/dm+geronimos+red+fox Pictured here at two…$2,500
Aqha Pending ~ DM Geronimo's Dawn ~ Bay/Bay Roan Filly ~ $2000.00 Blu Geronimo Hancock x BLH Two Eyed Peppy Pictured here at six weeks old. $500…$2,000
Gotta Run is a direct son of W.G.C. General's Armed and Dangerous. He was in the show ring till 8 years of age. The last 2 years I have made a field…$2,500
Nasmat Burkan (Nasmat Asfour x Ahlem Baselah by Shahir IASB) 2013 Grey Stallion Straight Egyptian Arabian Standing At public service until sold (Breeding…$3,500
*** INQUIRE FOR PRICING AND POSSIBLE PACKAGE DEAL!*** Ansata Jalila (Ansata Qasim x Ansata Jalala by Ansata Iemhotep) 2009 Grey Mare Straight Egyptian…$1


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Tobby's Tribute
All about Tobby
Pet Tip
Pulling Dogs – Pet tip 166
Trying to walk a large strong dog is usually difficult for novice dog owners and even some experienced dog owners. Especially when the dog has had no obedience training, pulling is a common behaviour that dogs will engage in on …
- Owner:
- cassie bowers
- City:
- sparks
- Province, Country:
- NV, United States
- Type/Breed:
- australian/german shepard mix
- Date of Birth:
- 1993
- Date of Death
- 2006
- Sex:
- Male
- Height:
- 36
- Weight:
- Not Provided
- Coat Colour:
- black/gray
- Eye Colour:
- one brown one gray
Toby was a wonderful dog even though he bit a few kids he was still a sweet dog that just wanted to protect his family. He was brave even though he was small and if you met him you would fall in love with him and just because he was blind in one eye he was still hansome.
I love you Tobby
and ill never forget you


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Trzebinia Vacation Packages
Trzebinia is situated approximately 160 miles (257 kilometers) southwest of Warsaw, the country's capital, and approximately 20 miles (32 kilometers) west of Krakow.
From perennial tourist favourites to lesser known nooks and crannies, Krakow - Lesser Poland is brimming with things to do and see. If you're keen to explore more of the area, head 16 miles (26 kilometers) to Ojcow. Here you can pay a visit to the Ojcow National Park and Pieskowa Skala.
Around 20 miles (32 kilometers) to the west of Trzebinia is Katowice, a regional center which is home to University of Silesia, Silesia City Center and Parachute Tower Katowice. Katowice International Fair, Silesian Museum and Goldstein Palace are also worth calling into while you are here.
If you want to stay indoors, head to Krakow - Lesser Poland 's excellent history museums, theaters and art museums. These are great places to to soak up some of the region's rich cultural tapestry and pick up an unusual souvenir. Tourists looking for quiet places to reflect upon life's great mysteries, will love visiting some of the area's cathedrals.
Should you hear the call of the great outdoors, follow the lead of active locals and spend the day hiking or bungee jumping.
When it's time to leave this special part of the world, say a fond Narazie (farewell) to the characters you have met and the spots you've enjoyed.


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intern government relations jobs near Washington, DC
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Intelligence Analysis Summer Intern Program
National Security Agency - Fort George G Meade, MD
Interns will receive the following benefits:. Interns are hired on a temporary appointment, and are not eligible for health insurance, life insurance, or Thrift...
PR Account Executive
W2 Communications - McLean, VA
Past experience in public relations, corporate communications or content marketing. Need to have experience in managing interns, Account Coordinators, Senior...
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American Enterprise Institute - Washington, DC
The Media Relations Coordinator will work directly with the Executive Director of Media Relations and Strategic Marketing to execute media strategy to promote...
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General Dynamics Information Technology - Fairfax, VA
Media relations writing and communication campaigns. As a trusted systems integrator for more than 50 years, General Dynamics Information Technology provides...
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CollegeBoard - Washington, DC
The Policy interns will have a unique opportunity to work in a fast-paced environment while gaining real-world experience with postsecondary policy development,...
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Strong interest in government relations and/or communications. Interns are provided a challenging and stimulating work environment....
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The intern will perform research; The National Governors Association (NGA)seeks an experienced professional to join us as an Intern in the Office of Federal...
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He or she will learn about government relations and stakeholder engagement that supports the successful outreach strategies of a large nonprofit research...
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The Office of Government Relations & Public Affairs at the National Endowment for Democracy (NED) is seeking a highly motivated individual to serve as an Intern...


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Midnight circus tent lit at night
Credit: Image by Catherine MacBride
Creative #: 142323378
Licence type: Rights-managedRights-managed products are licensed with restrictions on usage, such as limitations on size, placement, duration of use and geographic distribution. You will be asked to submit information concerning your intended use of the product, which will determine the scope of usage rights granted.
Collection: Moment
Max file size: 9,000 x 6,000 px (76.20 x 50.80 cm) - 300 dpi - 24.8 MB
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Midnight Circus Tent Lit At Night Stock PhotoArts Culture and Entertainment,Circus,Circus Tent,Colour Image,Dublin - Republic of Ireland,Elevated View,Horizontal,Illuminated,Ireland,Midnight,Night,No People,Outdoors,Photography,Small,Town,TreePhotographer Image by Catherine MacBrideCollection: Moment © Catherine MacBride 2012Little lit circus tent and town at night, Dublin.


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fesoterodine (cont.)
What should I discuss with my healthcare provider before taking fesoterodine (Toviaz)?
You should not use this medication if you are allergic to fesoterodine or tolterodine (Detrol), or if you have:
To make sure you can safely take fesoterodine, tell your doctor if you have any of these other conditions:
FDA pregnancy category C. It is not known whether fesoterodine will harm an unborn baby. Tell your doctor if you are pregnant or plan to become pregnant while using this medication.
It is not known whether fesoterodine passes into breast milk or if it could harm a nursing baby. Do not use this medication without telling your doctor if you are breast-feeding a baby.
Fesoterodine is not for use in children.
Adults who are 75 years or older may be more likely to have side effects from this medication.
How should I take fesoterodine (Toviaz)?
Take exactly as prescribed by your doctor. Do not take in larger or smaller amounts or for longer than recommended. Follow the directions on your prescription label.
Take this medication with water.
Do not crush, chew, or break an extended-release tablet. Swallow it whole. Breaking or opening the pill may cause too much of the drug to be released at one time.
Store at room temperature away from moisture and heat.
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Report Problems to the Food and Drug Administration
You are encouraged to report negative side effects of prescription drugs to the FDA. Visit the FDA MedWatch website or call 1-800-FDA-1088.
Need help identifying pills and medications?


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Friday, May 27, 2016
Forced Individual Arbitration of Wage-and-Hour Claims Violates NLRA
The Seventh Circuit Court of Appeals, in an opinion by Judge Diane Wood, held that forcing an employee to agree to bring any wage-and-hour claim through individual arbitration violated the National Labor Relations Act. Lewis v. Epic Systems Corp., No. 15-2997 (7th Cir. May 26, 2016).
Epic sent an email to some employees with an agreement requiring them to bring wage-and-hour claims only through individual arbitration and to waive the right to participate in any class, collective, or representative proceeding. The email said that employees were "deemed to have accepted this Agreement" if they continued to work at Epic.
Plaintiff agreed at the time, but later sued Epic in federal court for violations of the overtime requirements of the Fair Labor Standards Act and Wisconsin law. Epic moved to compel individual arbitration.
Section 7 of the NLRA provides that "[e]mployees shall have the right to self- organization, to form, join, or assist labor organizations, to bargain collectively through representatives of their own choosing, and to engage in other concerted activities for the purpose of collective bargaining or other mutual aid or protection." 29 U.S.C. § 157. The Seventh Circuit stated, "Section 7's 'other concerted activities' have long been held to include 'resort to administrative and judicial forums.'" The court held that "the phrase 'concerted activities' in Section 7 should be read broadly to include resort to representative, joint, collective, or class legal remedies." Thus, "insofar as it prohibits collective action, Epic's arbitration provision violates Sections 7 and 8 of the NLRA."
Further, the Federal Arbitration Act did not "save[] the ban on collective action." The district court's denial of the motion to compel arbitration was affirmed.
May 27, 2016 in Class Actions, Recent Decisions | Permalink | Comments (0)
Wednesday, May 25, 2016
Goings-On in the Committee that Never Sleeps (a/k/a the Civil Rules Advisory Committee)
The indefatigable Advisory Committee on Civil Rules met on April 14, 2016 and prepared a report to the Committee on Rules of Practice and Procedure (the Standing Committee), which will meet June 6-7, 2016. The report begins at page 251 of the Agenda book, and the draft minutes of the April 14 meeting begin at page 489 of the Agenda book.
The report has three parts. First, the Advisory Committee recommends that the Standing Committee approve proposed amendments to Rule 5 (e-service and e-filing), Rule 23 (class actions), and Rule 62 (stays of execution of judgment) for publication this summer.
Second, the Advisory Committee recommends that the Standing Committee approve two pilot projects for submission to the Judicial Conference. The first pilot project would test a system of mandatory initial disclosures that would be more robust than those currently required by Rule 26(a)(1). The second pilot project would test the effectiveness of court-wide adoption of practices to reduce "cost and delay."
Third, the Advisory Committee:
(a) "describes proposals under active consideration for eventual publication and adoption," including:
- a new subdivision of Rule 5.2 dealing with redaction (super exciting stuff!);
- studying "concerns about the operation of Rule 30(b)(6)(deposition of an entity)"; and
- "consideration of the Rule 81(c) provisions for demanding a jury trial after a case is removed from state court"; and
(b) briefly mentions suggestions for rules amendments that the Committee has "removed from the agenda" (i.e., rejected for now), including:
- the "separate document" requirement of Rule 58;
- suggestions to assist pro se litigants;
- amending the pleading standard in Rule 8(a)(2) ("The time has not yet come for such a project."); and
- mandatory disclosure of third-party financing arrangements.
In future posts, I will discuss some of these developments in more detail.
May 25, 2016 in Class Actions, Federal Courts, Federal Rules of Civil Procedure | Permalink | Comments (0)
Wednesday, May 18, 2016
SCOTUS Vacates Ninth Circuit in Spokeo, Remands for New "Concreteness" Inquiry
The Supreme Court issued Spokeo, Inc. v. Robins, No. 13-1339, earlier this week. In a majority opinion unlikely to make anyone happy, the Court vacated the Ninth Circuit's decision, which held that Robins had adequately alleged Article III standing, and remanded.
A Brief Recap
Robins' complaint alleged that Spokeo maintained an inaccurate consumer report about him on its website, in violation of the Fair Credit Reporting Act's requirement that consumer reporting agencies "follow reasonable procedures to assure maximum possible accuracy of the information concerning the individual about whom the report relates." In particular, Robins alleged that a photo purporting to be Robins on the site wasn't him, and that the site incorrectly stated that he was in his 50s, married, employed in a professional or technical field, has children, has a graduate degree, and is in the top 10% for wealth.
The upshot of this disseminated misinformation, Robins alleged, was that when he was "out of work" and "actively seeking employment," he encountered "[imminent and ongoing] actual harm to [his] employment prospects."
The Majority Opinion
You wouldn't know that Robins alleged actual harm to his employment prospects by reading the majority opinion, which didn't mention it. Instead, the majority opinion by Justice Alito (joined by Roberts, Kennedy, and Thomas and inexplicably by Breyer and Kagan) managed to further stultify constitutional standing doctrine by seizing on the Court's prior repetition of the phrase "concrete and particularized" in describing the "injury in fact" required for standing. The Court now finds it obvious that these are separate, distinct requirements: (1) concrete and (2) particularized (although the Court cited no case that actually discussed these terms separately). The Ninth Circuit, held the majority, applied the "particularized" branch but not the "concreteness" branch.
May 18, 2016 in Class Actions, Standing, Subject Matter Jurisdiction, Supreme Court Cases | Permalink | Comments (0)
Friday, March 25, 2016
SCOTUS Decision in Tyson Foods v. Bouaphakeo: Another Important Case on Class Actions
This week the Supreme Court issued its decision in Tyson Foods, Inc. v. Bouaphakeo, covered here, here, and here. Tyson Foods is one of several important class action cases on the Court's docket this Term—and the second one decided so far. Like Campbell-Ewald back in January, the Tyson Foods decision is generally good news for proponents of class actions. By a 6-2 vote, the Court upheld class certification under Rule 23(b)(3).
Justice Kennedy wrote the majority opinion, joined by Chief Justice Roberts and Justices Ginsburg, Breyer, Sotomayor, and Kagan. Chief Justice Roberts wrote a separate concurring opinion, which was joined in part by Justice Alito. Justice Thomas wrote a dissenting opinion, which Justice Alito joined. All the opinions are worth a read, but below are a few highlights from Justice Kennedy's majority opinion.
First, Justice Kennedy emphasized that the presence of some individualized issues is not fatal to Rule 23(b)(3)'s predominance requirement:
The predominance inquiry "asks whether the common, aggregation-enabling, issues in the case are more prevalent or important than the non-common, aggregation-defeating, individual issues." [2 W. Rubenstein, Newberg on Class Actions], §4:49, at 195–196. When "one or more of the central issues in the action are common to the class and can be said to predominate, the action may be considered proper under Rule 23(b)(3) even though other important matters will have to be tried separately, such as damages or some affirmative defenses peculiar to some individual class members." 7AA C. Wright, A. Miller, & M. Kane, Federal Practice and Procedure §1778, pp. 123–124 (3d ed. 2005) (footnotes omitted).
Justice Kennedy also provided some important guidance on the Supreme Court's 2011 Wal-Mart decision, clarifying that "Wal-Mart does not stand for the broad proposition that a representative sample is an impermissible means of establishing class-wide liability." He recognized the practical reality that "[i]n many cases, a representative sample is 'the only practicable means to collect and present relevant data' establishing a defendant's liability. Manual of Complex Litigation §11.493, p. 102 (4th ed. 2004)." And:
In a case where representative evidence is relevant in proving a plaintiff's individual claim, that evidence cannot be deemed improper merely because the claim is brought on behalf of a class. To so hold would ignore the Rules Enabling Act's pellucid instruction that use of the class device cannot "abridge . . . any substantive right." 28 U. S. C. §2072(b).
The Court ultimately did not resolve the second question in Tyson Foods, which was originally framed as "whether a class may be certified if it contains 'members who were not injured and have no legal right to any damages.'" After noting that Tyson Foods had "reframe[d] this argument" in its merits brief, Justice Kennedy declined to address it "because the damages award has not yet been disbursed, nor does the record indicate how it will be disbursed." The Court therefore remanded the case, recognizing that Tyson Foods "may raise a challenge to the proposed method of allocation when the case returns to the District Court for disbursal of the award." In his final paragraph of analysis, however, Justice Kennedy noted that the potential for "uninjured class members" to recover from the class judgment appeared to be a problem "of [Tyson Foods'] own making," because Tyson Foods had argued against having bifurcated liability and damages proceedings.
For additional coverage, check out:
- Perry Cooper (Bloomberg)
- Lyle Denniston (SCOTUSblog)
- Alexandra Lahav (Mass Tort Litigation Blog)
- Adam Liptak (New York Times)
March 25, 2016 in Class Actions, Federal Courts, Federal Rules of Civil Procedure, Recent Decisions, Supreme Court Cases | Permalink | Comments (0)
Friday, March 18, 2016
Seiner on Class Actions in the Technology Sector
Joe Seiner has posted on SSRN a draft of his essay, Tailoring Class Actions to the On-Demand Economy, which will be published in the Ohio State Law Journal. Here's the abstract:
In O'Connor v. Uber, 2015 WL 5138097 (N.D. Cal. Sept. 1, 2015), a federal district court permitted a class-action case to proceed on the question of whether 160,000 drivers were misclassified by their employer as independent contractors rather than employees. The case has garnered widespread interest, making headlines across the country. Yet it represents only one of many class-action cases currently pending against technology companies in the modern economy. Indeed, similar systemic claims have already been brought against Yelp, GrubHub, Handy, Crowdflower, Amazon, and many others.
The courts have largely floundered in their efforts to address the proper scope of class cases brought against corporations in the on-demand economy. This is likely the result of a lack of clarity in this area as well as the unique fact patterns that often arise with technology-sector claims. Nothing has been written on this issue in the academic literature to date, and this paper seeks to fill that void in the scholarship.
Navigating the statutes, case law, and procedural rules, this Essay proposes a workable five-part framework for analyzing systemic claims brought in the technology sector. This paper sets forth a model for the courts and litigants to follow when evaluating the proper scope of these cases. The Essay seeks to spark a dialogue on this important — yet unexplored — area of the law.
March 18, 2016 in Class Actions, Recent Scholarship, Web/Tech | Permalink | Comments (0)
Tuesday, February 23, 2016
Dodson on Opt-In Class Actions
Scott Dodson (Hastings) has posted An Opt-In Option for Class Actions
February 23, 2016 in Class Actions, Recent Scholarship | Permalink | Comments (0)
Thursday, February 11, 2016
Morley on Injunctive Relief and De Facto Class Actions
Michael Morley has posted on SSRN a draft of his article, De Facto Class Actions? Injunctive Relief in Election Law, Voting Rights, and Other Constitutional Cases. Here's the abstract:
When a court holds that a legal provision is unconstitutional; inconsistent with, or preempted by, federal law; or invalid under an agency's organic statute or a framework statute such as the Administrative Procedures Act, the court must decide whether to grant injunctive relief and, if so, how broad that relief should be. In particular, the court must decide whether to issue a Plaintiff-Oriented Injunction or a Defendant-Oriented Injunction. A Plaintiff-Oriented Injunction bars the government defendants from enforcing the challenged provision only against the plaintiffs in the case or affected members of plaintiff organizations. A Defendant-Oriented Injunction, in contrast, completely bars the government defendant from enforcing the challenged provision against anyone in the state or nation.
Many courts tend to award Defendant-Oriented Injunctions in election law and voting rights cases, even when they are not brought as class actions, without recognizing or addressing most of the pertinent issues that choice implicates. Individual plaintiffs typically lack Article III standing to seek relief protecting the rights of third parties not before the court. And such third parties may neither fall within the court's personal jurisdiction nor wish to challenge the provision at issue. Defendant-Oriented Injunctions in non-class cases also raise asymmetric preclusion concerns, undermine the policy considerations underlying Rule 23, and allow trial courts to enforce their rulings beyond the geographic limits of their jurisdiction.
February 11, 2016 in Class Actions, Recent Scholarship | Permalink | Comments (0)
Tuesday, February 9, 2016
Choi and Pritchard on SEC Investigations and Securities Class Actions
A new article by Professors Stephen J. Choi and A.C. Pritchard, SEC Investigations and Securities Class Actions: An Empirical Comparison, has been published in the Journal of Empirical Legal Studies.
Using actions with both an SEC investigation and a class action as our baseline, we compare the targeting of SEC-only investigations with class-action-only lawsuits. Looking at measures of information asymmetry, we find that investors in the market perceive greater information asymmetry following the public announcement of the underlying violation for class-action-only lawsuits compared with SEC-only investigations. Turning to sanctions, we find that the incidence of top officer resignation is greater for class-action-only lawsuits relative to SEC-only investigations. Our findings are consistent with the private enforcement targeting disclosure violations at least as precisely as (if not more so than) SEC enforcement.
February 9, 2016 in Class Actions, Recent Scholarship | Permalink | Comments (0)
Palmer on Partisan Appointments to Special Courts and Panels
A new article, Does the Chief Justice Make Partisan Appointments to Special Courts and Panels?, by political science professor Maxwell Palmer (Boston University), has been published in the Journal of Empirical Legal Studies.
The Chief Justice of the Supreme Court has the exclusive and independent power to appoint federal judges to various special courts and panels, including the Foreign Intelligence Surveillance Court (FISC), the court that oversees all domestic surveillance for national security, including domestic data collection by the National Security Agency (NSA). This article examines the propensity of Chief Justices to appoint co-partisan judges to these panels. Such appointments may serve to produce decisions and policies that align with the Chief Justice's preferences. I use computational simulations to model the appointment decisions made by Chief Justices. I find that there is less than a 1 percent chance that a neutral Chief Justice would appoint as many Republicans to the FISC as have been appointed in the last 36 years. I further show that the Chief Justice is not selecting appointees on other observable judicial characteristics, such as age, experience, gender, senior status, or caseload. These results have important implications for the creation of judicial institutions, the internal politics of the judiciary, legislative delegation, and the powers and oversight of the national security state.
February 9, 2016 in Class Actions, Federal Courts, Recent Scholarship | Permalink | Comments (0)
Friday, January 22, 2016
Article on Spokeo, Inc. v. Robins Now on St. Thomas Journal of Complex Litigation Website
I'm overcoming my reticence to post twice about one of my articles, because I want to promote the law students at St. Thomas University School of Law who have labored to establish the new St. Thomas Journal of Complex Litigation (JCL). The final version of my article, "Spokeo, Inc. v. Robins: The Illusory 'No-Injury' Class Reaches the Supreme Court," has just been posted on the JCL website. The abstract is available on SSRN here.
The St. Thomas JCL is pleased to accept submissions through ExpressO or Scholastica from judges, attorneys, law faculty, and law students. Information on submissions is here.
January 22, 2016 in Class Actions, Recent Scholarship, Standing, Supreme Court Cases | Permalink | Comments (0)
Wednesday, January 20, 2016
Today's SCOTUS Decision in Campbell-Ewald v. Gomez
The Supreme Court issued its decision today in Campbell-Ewald Co. v. Gomez, a closely watched case on class actions, Article III, and mootness (covered earlier here and here). Justice Ginsburg's majority opinion begins:
Is an unaccepted offer to satisfy the named plaintiff 's individual claim sufficient to render a case moot when the complaint seeks relief on behalf of the plaintiff and a class of persons similarly situated? This question, on which Courts of Appeals have divided, was reserved in Genesis HealthCare Corp. v. Symczyk, 569 U. S. ___, ___, ___, n. 4 (2013) (slip op., at 5, 6, n. 4). We hold today, in accord with Rule 68 of the Federal Rules of Civil Procedure, that an unaccepted settlement offer has no force. Like other unaccepted contract offers, it creates no lasting right or obligation. With the offer off the table, and the defendant's continuing denial of liability, adversity between the parties persists.
Justice Ginsburg's opinion is joined by Justices Kennedy, Breyer, Sotomayor, and Kagan. Justice Thomas adds a sixth vote, but writes a separate concurring opinion. Chief Justice Roberts writes a dissenting opinion, joined by Justices Scalia and Alito, and Justice Alito writes a dissenting opinion as well.
January 20, 2016 in Class Actions, Federal Courts, Federal Rules of Civil Procedure, Recent Decisions, Subject Matter Jurisdiction, Supreme Court Cases | Permalink | Comments (0)
Friday, January 15, 2016
SCOTUS Cert Grant in Microsoft v. Baker: Appellate Review of Orders Denying Class Certification
Today the Supreme Court granted certiorari in Microsoft Corp. v. Baker, limited to the following Court-generated question:
Whether a federal court of appeals has jurisdiction under both Article III and 28 U.S.C. § 1291 to review an order denying class certification after the named plaintiffs voluntarily dismiss their individual claims with prejudice.
You can find all the cert-stage briefing—and follow the merits briefs as they come in—at SCOTUSblog.
January 15, 2016 in Class Actions, Federal Courts, Federal Rules of Civil Procedure, Recent Decisions, Subject Matter Jurisdiction, Supreme Court Cases | Permalink | Comments (0)
Sunday, January 10, 2016
House Passes Bill Aimed to Stifle Class Actions
On January 8, the House of Representatives passed the Fairness in Class Action Litigation and Furthering Asbestos Claim Transparency Act of 2016. (The L.A. Times called the "fairness in class action" part of the title "Orwellian" and "shameless[].")
For additional coverage of the bill, see our post from last Friday.
The bill goes to the Senate next for consideration.
January 10, 2016 in Class Actions, Current Affairs, Mass Torts, MDLs | Permalink | Comments (1)
Friday, January 8, 2016
House to Vote on Bill Strictly Limiting Class Actions
The House of Representatives is close to taking up a bill (H.R. 1927) that some are calling the "Volkswagen bail-out bill" due to its stymieing effect on class actions. Another part of the bill, the Huffington Post charges, "would force the online disclosure of sensitive personal information of sick and dying asbestos victims seeking compensation for their illnesses."
When we last reported on this bill, it dealt only with class actions. That bill has now been amended and combined with another bill on asbestos claims, resulting in the "Fairness in Class Action Litigation and Furthering Asbestos Claim Transparency Act of 2015."
The latest draft of the portion of the bill on class actions reads as follows:
(a) IN GENERAL.—No Federal court shall certify any proposed class seeking monetary relief for personal injury or economic loss unless the party seeking to maintain such a class action affirmatively demonstrates that each proposed class member suffered the same type and scope of injury as the named class representative or representatives.
(b) CERTIFICATION ORDER.—An order issued under Rule 23(c)(1) of the Federal Rules of Civil Procedure that certifies a class seeking monetary relief for personal injury or economic loss shall include a determination, based on a rigorous analysis of the evidence presented, that the requirement in subsection (a) of this section is satisfied.
The House Judiciary Committee has issued House Report 114-328 on the class action portion of the bill. The Democrats opposing the bill stated in their dissenting views that the bill is "a solution in search of a problem" and "represents the latest attempt to shield corporate wrongdoers and deny plaintiffs access to justice." They concluded:
H.R. 1927 is an unnecessary bill that threatens to deny millions of plaintiffs access to Federal courts by creating potentially insurmountable obstacles to class action certification and raising litigation costs. Moreover, it disrespects the Federal courts by imposing new burdens on them and by circumventing the congressionally created Rules Enabling Act process by which Federal civil procedure rules are amended after extensive input from the bench and bar.
Meanwhile, at the annual meeting of the Association of American Law Schools, members of the Advisory Committee on Civil Rules are scheduled to discuss potential class actions reforms today. I am not at the conference this year, and would be interested to learn if anyone mentions H.R. 1927 and how that bill might relate to proposals before the Advisory Committee.
The House yesterday passed a resolution limiting amendments to and debate on the bill.
Professor Alexandra D. Lahav testified against the bill last April.
January 8, 2016 in Class Actions, Current Affairs, Mass Torts | Permalink | Comments (0)
Wednesday, December 16, 2015
CAFA Governs Attorneys' Fees in Class Settlement Involving Michaels' Vouchers
An interesting opinion by U.S. District Judge William G. Young:
- provides a definition of "coupons" as used in the Class Action Fairness Act;
- makes sense of the "poorly drafted" CAFA provision regulating attorneys' fees in so-called coupon settlements; and
- incidentally speculates on the relationship between MDL case assignment, the potential loss of judgeships in a district, and the strictness of a district judge's scrutiny of attorneys' fees in class action settlements.
Tyler v. Michaels Stores, Inc., No. CV 11-10920-WGY, 2015 WL 8484421 (D. Mass. Dec. 9, 2015).
This class action, based on Massachusetts consumer law, alleged that Michaels "asked customers for their zip codes as part of credit card transactions to reverse engineer those customers' addresses using commercially available databases, and then used those addresses to carry out aggressive and unwanted marketing campaigns." [Internal quotation marks omitted.] After Michaels moved to dismiss, the federal court certified legal questions to the Supreme Judicial Court of Massachusetts, which held plaintiffs' allegations sufficient under state law.
After discovery, the parties settled and the court approved the settlement, reserving a ruling on class counsel's request for fees. Under the settlement, class members were to receive a $10.00 or $25.00 "voucher" to be used on any merchandise in Michaels' physical stores, with certain restrictions on use. The face value of the vouchers was $418,000.00. The value of the vouchers actually redeemed by class members was $138,620.00.
Class counsel requested fees and costs of $425,000.00, asserting that Massachusetts law, not CAFA, governed the fees request because the vouchers were not "coupons" as used in CAFA, 28 U.S.C. § 1712, which applies to settlements that "provide[] for a recovery of coupons to a class member." Surprisingly, CAFA does not define "coupon." Surveying other cases, the Court "essay[ed] such a definition: when class members must transact business with the defendant to obtain the benefit of the settlement, the settlement 'provides for a recovery of coupons' under section 1712. In other words, coupons must be redeemed; conversely, if an award must be redeemed, it is a coupon." Under that definition, the Michaels vouchers were coupons, and section 1712 applied to the fees request.
That didn't settle the matter, however, because section 1712 is bewilderingly drafted. (I won't reprint it here: just read subsections (a), (b), and (c), if you dare, and see if you can decipher them.) Again after surveying other cases, the Court held that even in a coupon-only settlement, section 1712 "vests the Court with the discretion to choose between using a percentage-of-coupons-redeemed method, or the lodestar method."
Here, the Court chose the lodestar method (attorney hours worked times hourly fee) for two reasons: "[f]irst, class counsel vindicated the important public policy goals of Massachusetts' consumer protection statute," and "[s]econd, and most importantly, they obtained binding precedent from the Supreme Judicial Court that will influence conduct far beyond that of Michaels." However, the Court warned:
Given the hostility to disproportionately large fee awards to class counsel evident in the legislative history -- at least insofar as fees generated from obtaining coupon settlements were concerned -- counsel may reasonably expect that this Court will generally award attorneys' fees based on a percentage of the actual value of the coupons redeemed by class members, absent the groundbreaking nature of this case.
[Footnotes omitted.]
The Court found that the requested hourly fee of $650.00 for partners was unreasonable, and cut it to $350.00. This yielded a lodestar of $312,895.00 in attorneys' fees, which was awarded along with $14,005.30 in costs.
In other words, the fees award, even though reduced from what was requested, still ended up being more than twice as much as the value of the vouchers actually redeemed by class members. Personally, I have no problem with that: in my opinion, the primary purpose of the consumer class action is not to compensate the plaintiff class, but to hold the defendant accountable for violating the law. Others obviously disagree.
Here's where the Court's two-page footnote 29 comes in. The Court's point appears to be this: at least one pro-business advocacy group has argued to the Judicial Panel on Multidistrict Litigation that the Panel's decision where to send an MDL should "rest on a district judge's strict scrutiny of claims for attorneys' fees in class action settlements." In other words, business interests have argued that the more strictly a district judge scrutinizes fees requests, the more that judge should be favored as the transferee court in an MDL. But why should judges want to be the transferee court in an MDL? Because all of those transferred cases will now be counted as part of that judge's, and that district's, civil caseload. (When a civil case is filed in one district, and transferred to another district for whatever reason, including MDL, it is counted as a filing in both the transferor and the transferee court. So, for example, if the Panel transfers 5,000 MDL cases to another district, the transferee district gets 5,000 cases added to its total filings.) This accrual of cases "tend[s] to immunize that court against the potential loss of a judgeship," because recommendations by the Judicial Conference to add or subtract authorized district court judgeships are based in part on the number of case filings that district has.
So the Court in Tyler candidly "confess[ed] that, when awarding attorneys' fees in this case, it contemplated -- but rejected as wholly inappropriate -- an additional consideration: the views of the Judicial Panel on Multidistrict Litigation."
December 16, 2015 in Class Actions, MDLs, Recent Decisions | Permalink | Comments (0)
Monday, December 14, 2015
SCOTUS Decision in DIRECTV v. Imburgia: Federal Arbitration Act Overrides State Contract Law (Again)
Today the Supreme Court issued its decision in DIRECTV, Inc. v. Imburgia. The vote was 6-3, with Justice Breyer writing the majority opinion. Justice Thomas writes a dissenting opinion, and Justice Ginsburg writes a dissenting opinion joined by Justice Sotomayor.
As covered earlier here and here, Imburgia is another case involving the Federal Arbitration Act (FAA). The particular issue is whether the FAA allows California to construe an arbitration provision referring to California state law (the "law of your state") to mean state law as it existed prior to the U.S. Supreme Court invalidating certain aspects of California contract law in its 2011 decision in AT&T Mobility LLC v. Concepcion. That was how the California Court of Appeal construed the arbitration agreement in Imburgia, but Justice Breyer's majority opinion disagrees, concluding instead that such a construction itself violates the FAA by failing to "place arbitration contracts on equal footing with all other contracts."
December 14, 2015 in Class Actions, Recent Decisions, Supreme Court Cases | Permalink | Comments (1)
Monday, November 16, 2015
Public Interest Group Reports on November 5 Advisory Committee Meeting
Valerie Nannery, Senior Litigation Counsel for the Center for Constitutional Litigation, attended the November 5, 2015 meeting of the Advisory Committee on Civil Rules (agenda here) in Salt Lake City, Utah, and reported on the meeting in the Center's blog.
Highlights from the Center's report:
Rule 23: "The Committee has taken a 'settlement class' rule off of the agenda, and has put 'ascertainability' and Rule 68 on hold. The Committee also approved taking cy pres and 'issue classes' off of the agenda."
Duke Center's private "Guidelines" on proportionality in discovery: "the Duke guidelines and any presentation at the conferences do not come with the imprimatur of the Rules Committees," and "The Duke Center, like other groups, is free to hold conferences or propose guidelines with respect to the rules or any other area of law. But they are not entitled to communicate, or suggest, that they bear the stamp of approval of the Rules Committees."
November 16, 2015 in Class Actions, Federal Rules of Civil Procedure | Permalink | Comments (0)
Friday, November 13, 2015
Moore on Spokeo, Inc. v. Robins
I have recently posted on SSRN an article, "Spokeo, Inc. v. Robins: The Illusory 'No-Injury' Class Reaches the Supreme Court." The article is forthcoming in the newly-established St. Thomas Journal of Complex Litigation, which is currently welcoming submissions.
The Supreme Court's grant of certiorari in Spokeo, Inc. v. Robins, 135 S. Ct. 1892 (Mem.) (2015) casts a shadow on the long-accepted constitutional principle that Congress has the authority to enact a statute to regulate corporations' behavior for the public good, and to provide a private right of action to a person as to whom the statute is violated. That right of action often provides for the award of a minimum amount of statutory damages as an alternative or in addition to actual damages.
Congress has enacted numerous such statutes, including the one at issue in Spokeo, the Fair Credit Reporting Act ("FCRA"), which was passed forty-five years ago. Suddenly, within the last ten years, corporate litigation activists have invented a new argument to avoid regulatory statutes that provide for statutory damages. They claim that a "mere" statutory violation is an "injury in law" rather than the "injury in fact" required for Article III standing. And they are launching a frontal assault on Congress's constitutional authority to enact any statute that provides a private right of action for its violation, accusing Congress of thereby violating Article III by "creating standing."
Corporate litigation activists then apply to a class representative the argument that the violation of a person's statutory rights is not an "injury in fact," and call the result a "no-injury class." The appellation "no-injury class" is another misleading verbal weapon of recent vintage.
This article hopes to makes three small contributions to the burgeoning literature on Spokeo, which at this writing has not yet been decided. First, the Question Presented to the Supreme Court is misleading and overbroad. It implies that the plaintiff in Spokeo, Thomas Robins, has been found not to have suffered any "concrete harm," but the case is still at the pleading stage. Thus, the question is simply whether Robins's complaint contains sufficient allegations of injury, assumed to be true on a motion to dismiss, to establish Article III standing. Further, the Question Presented implies that a ruling involving the FCRA (the statute at issue in Spokeo) will be generalizable to all other statutes that create a private right of action and allow statutory damages, without recognizing the many variations in these statutes' language and operation.
Second, the article sketches the historical legal difference between the words "injury" and "damage." "Injury" connotes the violation of one's legal right, even if one has not sustained any actual harm, while "damage" means a loss or harm, even if one has no legal right to sue. The Supreme Court has adhered to these meanings since Marbury v. Madison. Given that historical distinction, the term "injury in fact" is confusing and somewhat self-contradictory: under the definition of "injury" as the violation of a legal right, the term "injury in fact" is akin to "violation of a legal right in fact." Further, the petitioner Spokeo's newly-discovered phrase "injury in law" – which has never been used in a single United States Supreme Court opinion -- is redundant. Under the definition of "injury" as the violation of a legal right, the phrase "injury in law" is akin to "legal right in law." But however nonsensical, the epithet "injury in law" serves a useful purpose for corporate activists: it minimizes, even ridicules, so-called "technical," "trifling" statutes that regulate corporate behavior.
Finally, the petitioner Spokeo and its numerous business-oriented amici could have made the very same argument they are making in Spokeo – that the violation of the Fair Credit Reporting Act is not itself an "injury in fact" – only nine years ago in Safeco Insurance Co. v. Burr, 551 U.S. 47 (2007), but did not. In Safeco, the putative class alleged that insurers Safeco and GEICO had not complied with the FCRA's requirement of sending the class members notice of an "adverse action" when the insurers did not charge them the lowest available insurance rate because of a less-than-perfect credit report. The defendants' amici repeatedly stated that the plaintiffs in Safeco had not alleged any "actual harm" or "actual damages" even though they sought $1,000 in statutory damages for each member of the class (as the FCRA allows). Thus, Safeco presented exactly the same alleged "no-injury" situation, under exactly the same statute, as Spokeo. Yet the Safeco petitioners and their amici (four of which are also amici in Spokeo) failed to argue that the class representatives lacked Article III standing or that violation of the FCRA was not an "injury in fact." It seems fair to ask why not, if the Article III argument is so compelling. One might speculate that the reason is that corporate litigation activists have only recently contrived the "statutory-violation-is-not-an-injury-in-fact" argument.
November 13, 2015 in Class Actions, Recent Scholarship, Standing, Supreme Court Cases | Permalink | Comments (0)
Tuesday, November 10, 2015
Today's SCOTUS Oral Argument in Tyson Foods v. Bouaphakeo
The Supreme Court heard oral argument today in Tyson Foods, Inc. v. Bouaphakeo, which presents the questions:
(I) Whether differences among individual class members may be ignored and a class action certified under Federal Rule of Civil Procedure 23(b)(3), or a collective action certified under the Fair Labor Standards Act, where liability and damages will be determined with statistical techniques that presume all class members are identical to the average observed in a sample.
(II) Whether a class action may be certified or maintained under Rule 23(b)(3), or a collective action certified or maintained under the Fair Labor Standards Act, when the class contains hundreds of members who were not injured and have no legal right to any damages.
Here is the transcript. For our earlier coverage of the case, see here and here.
November 10, 2015 in Class Actions, Federal Courts, Federal Rules of Civil Procedure, Recent Decisions, Supreme Court Cases | Permalink | Comments (0)
Saturday, November 7, 2015
Wasserman on Fletcherian Standing, Merits, and Spokeo, Inc. v. Robins
Professor Howard Wasserman has posted on SSRN his essay, Fletcherian Standing, Merits, and Spokeo, Inc. v. Robins.
This essay offers an exercise in wishful jurisdictional and procedural thinking. As part of a Supreme Court Roundtable on Spokeo, Inc. v. Robins, it argues for William Fletcher's conception of standing as an inquiry into the substantive merits of a claim and of whether the plaintiff has a valid cause of action. This approach is especially necessary in statutory cases; along with its constitutional power to create new rights, duties, and remedies, Congress should have a free hand in deciding who and how those rights and duties should be enforced. Spokeo, which involves a claim for damages for publication of allegedly false consumer-credit information in violation of a federal statute, illustrates the wisdom and benefits of Fletcher's approach.
November 7, 2015 in Class Actions, Recent Scholarship, Standing | Permalink | Comments (1)


text:
[edit] Background
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[edit] Features
• Wii Balance Board
• Compatible with Wii MotionPlus


text:
Rent Women and Globalization 1st edition today, or search our site for other textbooks by Delia D. Aguilar. Every textbook comes with a 21-day "Any Reason" guarantee. Published by Humanity Books.
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text:
I don't make New Year's Resolutions. I don't think I ever really did, but the last decade or two would have been enough to stifle that impulse. I've just been too aware that I don't have that much control over what happens in my life.
Discuss the article on the Forums.
New Science article: Ruscetti standing by Mikovits & saying he did western blots
Discussion in 'Media, Interviews, Blogs, Talks, Events about XMRV' started by Esther12, Oct 4, 2011.
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