Civil Practice: Arbitration-Class Decertification-Unjust Enrichment

Where prison inmates brought a putative class action against a company that provides telephone services to correctional facilities, arguing that the rates and fees were unjust under the Federal Communications Act, the district  court did not err in decertifying the class after a decision by the D.C. Circuit because common questions no longer predominated, and the dismissal of the plaintiffs’ individual claims also is affirmed because the claims lacked the necessary predicate action by the agency, and the common-law unjust-enrichment claim was not available where a valid contract applied.

Judgment is affirmed.

Stuart v. Global Tel Link Corporation (MLW No. 74880/Case No. 18-2640 – 11 pages) (U.S. Court of Appeals, 8th Circuit, Colloton, J.) Appealed from U.S. District Court, Western District of Arkansas, Brooks, J. (Donna Siegel Moffa, Radnor, Pennsylvania, argued for appellant) (Derek T. Ho, Washington, D.C., argued for appellee).