Frank v. Gaos, 586 U.S. ___ (2019)
Plaintiffs brought class action claims against Google, claiming violations of the Stored Communications Act; they alleged that when an Internet user conducted a Google search and clicked on a hyperlink listed on the search results, Google transmitted information (referrer header) including the terms of the search to the server that hosted the selected webpage. The Act prohibits “a person or entity providing an electronic communication service to the public” from “knowingly divulg[ing] to any person or entity the contents of a communication while in electronic storage by that service” and creates a private right of action. The district court denied a motion to dismiss, citing a Ninth Circuit holding (Edwards) that an Article III injury exists whenever a statute gives an individual a statutory cause of action and the plaintiff claims that the defendant violated the statute.
The parties negotiated a classwide settlement that allowed the continued transmission of referrer headers but required Google to include disclosures on three of its webpages and to pay $8.5 million. None of those funds would be distributed to absent class members; most of the money would be distributed to cy pres recipients. In a class action, cy pres refers to distributing settlement funds not amenable to individual claims or meaningful pro rata distribution to nonprofit organizations whose work indirectly benefits class members. The balance would be used for administrative costs, given to the named plaintiffs, and awarded as attorney’s fees. In the meantime, the Supreme Court (Spokeo) held that “Article III standing requires a concrete injury even in the context of a statutory violation,” rejecting the "Edwards" premise. The Ninth Circuit affirmed approval of the settlement without addressing Spokeo.
The Supreme Court vacated. Although the Court granted certiorari to decide whether a class action settlement that provides a cy pres award but no direct relief to class members is “fair, reasonable, and adequate,” Fed. Rule Civ. Proc. 23(e)(2), the Court concluded that there is a substantial open question about whether any named plaintiff had standing. A court cannot approve a proposed class settlement if it lacks jurisdiction over the dispute, and federal courts lack jurisdiction if no named plaintiff has standing. When the district court ruled on the motion to dismiss, it relied on precedent that was subsequently abrogated in Spokeo.
Ninth Circuit's approval of a class action settlement in a case against Google is vacated and remanded for consideration of whether any of the named plaintiffs have standing, considering a 2016 Supreme Court holding: “Article III standing requires a concrete injury even in the context of a statutory violation.”
Motion of Paloma Gaos, et al. for divided argument submitted. |
Amicus brief of Public Citizen, Inc. and Public Citizen Foundation submitted. |
Amicus brief of State of Oregon submitted. |
Amicus brief of American Association for Justice submitted. |
Amicus brief of The Center for Democracy and Technology, The Electronic Frontier Foundation, and The National Consumers League submitted. |
Amicus brief of Law Professors submitted. |
Amicus brief of Professor William B. Rubenstein not accepted for filing. (Resubmitted with all required documentation - September 05, 2018) |
Amicus brief of Professor William B. Rubenstein submitted. |
Amicus brief of Spectrum Settlement Recovery, LLC submitted. |
Amicus brief of Center for Workplace Compliance submitted. |
Amicus brief of State of Oregon submitted. |
Amicus brief of Legal Aid Organizations submitted. |
Brief amicus curiae of Center for Workplace Compliance filed. |
Motion of the Solicitor General for leave to participate in oral argument as amicus curiae and for divided argument filed. |
Amicus brief of The New York Bar Foundation and The New York State Bar Association submitted. |
Amicus brief of Paloma Gaos, et al. submitted. |
Amicus brief of Computer & Communications Industry and Technet submitted. |
Amicus brief of Civil Justice Research Institute submitted. |
Motion of United States for leave to participate in oral argument and for divided argument submitted. |
Motion of Former Professor Roy A. Katriel for leave to participate in oral argument and for divided argument submitted. |
Motion for enlargement of time for oral argument, for leave to participate in oral argument as amicus curiae and for divided argument filed by Former Professor Roy A. Katriel. |
Brief of Google LLC submitted. |
Brief of respondents Paloma Gaos, et al. filed. |
Brief of Paloma Gaos, et al. submitted. |
Brief of respondent Google LLC filed. |
SET FOR ARGUMENT on Wednesday, October 31, 2018 |
Brief amici curiae of David Lowrey, et al. filed. |
Brief amicus curiae of New Jersey Civil Justice Institute filed. |
Amicus brief of American Bar Association not accepted for filing. (July 17, 2018 - Brief does not comply with Rules 33 & 34. To be reprinted.) |
Brief amicus curiae of Manhattan Institute for Policy Research filed. |
Brief amicus curiae of Center for Individual Rights filed. |
Brief amicus curiae of Chamber of Commerce of the United States of America in support of neither party filed. |
Brief amicus curiae of American Bar Association in support of neither party filed. |
Brief amici curiae of Attorneys General of Arizona, et al. filed. |
Brief amicus curiae of United States in support of neither party filed. |
Brief amicus curiae of Electronic Privacy Information Center filed. |
Brief amicus curiae of Lawyers for Civil Justice filed. |
Brief amici curiae of Center for Constitutional Jurisprudence and Atlantic Legal Foundation filed. |
Brief amicus curiae of Former Professor Roy A. Katriel in support of neither party filed. |
Brief amici curiae of Cato Institute and Americans for Prosperity filed. |
Amicus brief of Cato Institute not accepted for filing. (July 12, 2018) |
Brief of petitioners Theodore H. Frank, et al. filed. |
Joint appendix filed. (Statement of costs filed) |
Motion to extend the time to file the briefs on the merits granted. The time to file the joint appendix and petitioners' brief on the merits is extended to and including July 9, 2018. The time to file respondents' briefs on the merits is extended to and including August 29, 2018. |
Motion for an extension of time filed. |
Petition GRANTED. |
DISTRIBUTED for Conference of 4/27/2018. |
DISTRIBUTED for Conference of 4/20/2018. |
DISTRIBUTED for Conference of 4/13/2018. |
Reply of petitioners Theodore H. Frank, et al. filed. |
Brief of respondents Paloma Gaos, et al. in opposition filed. |
Brief of respondent Google LLC in opposition filed. |
Brief amicus curiae of Center for Constitutional Jurisprudence filed. |
Brief amicus curiae of Cato Institute filed. |
Brief amici curiae of Attorney General of Arizona, et al. filed. |
Brief amicus curiae of Center for Individual Rights filed. |
Motion to extend the time to file a response is granted and the time is extended to and including March 9, 2018, for all respondents. |
Motion to extend the time to file a response from February 7, 2018 to March 9, 2018, submitted to The Clerk. |
Petition for a writ of certiorari filed. (Response due February 7, 2018) |
Prior History
- In re Google Referrer Header Privacy Litigation, No. 15-15858 (9th Cir. Aug. 22, 2017)
- In re GOOGLE REFERRER HEADER PRIVACY LITIGATION, No. 5:2010cv04809 (N.D. Cal. Mar. 31, 2015)
The Ninth Circuit affirmed the district court's order approving the cy pres-only settlement arising from class action claims that Google violated users' privacy by disclosing their Internet search terms to owners of third-party websites. The panel held that the district court did not abuse its discretion in approving a cy pres- only settlement where the settlement funds were non-distributable; the district court did not abuse its discretion in finding the superiority requirement was met because the litigation would otherwise be economically infeasible; the district court did not abuse its discretion in approving the six cy pres recipients; the district court appropriately found that the cy pres distribution addressed the objectives of the Stored Communications Act and furthered the interests of the class members; a prior relationship or connection between the cy pres recipient and the parties or their counsel, without more, was not an absolute disqualifier; and the district court did not abuse its discretion by approving $2.125 million in fees and $21,643.16 in costs.