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LLC v. Directv, LLC

United States District Court, D. New Jersey

April 8, 2014

6803 BOULEVARD EAST, LLC, 728 KEARNY AVENUE, LLC, and 131-133 68th LLC, individually and on behalf of all others similarly situated, Plaintiffs,


WILLIAM H. WALLS, Senior District Judge.

Defendant DirecTECH Holding Co., Inc. ("DirecTech") moves for summary judgment on Plaintiffs' claims that DirecTech installed satellite equipment in common areas of their multiple dwelling unit rental properties (MDUs) in New Jersey without their consent. Under Federal Rule of Civil Procedure 78, the motion is decided without oral argument. DirecTech's motion for summary judgment is granted.


Plaintiffs are landlords who own and lease residential MDUs in New Jersey. Second Am. Compl. ¶ 1 (ECF No. 37). They brought a putative class action complaint in the Superior Court of New Jersey, Law Division: Hudson County against DIRECTV, which was removed to this Court. ECF No. 1. They allege that Defendants installed satellite equipment in common areas of their MDUs without their consent. Second Am. Compl. ¶ 1.

On July 31, 2012, the Court issued an opinion and order denying defendant DIRECTV, LLC's motion to dismiss or strike the class action claims. ECF Nos. 22, 23. The Court also granted Plaintiffs' motion to amend the complaint. Id. The complaint was subsequently amended for a second time on November 21, 2012, ECF No. 37, and discovery has been ongoing.

DirecTech filed the present motion on January 10, 2014, arguing that the undisputed facts show that DirecTech never installed any equipment on any of the named Plaintiffs' properties, meaning that the named Plaintiffs lack standing to maintain claims individually or as class representatives against DirecTech. DirecTech's Mem. of Law in Support of its Mot. for Summ. J. ("DirecTech's Mot. for Summ. J.") at 1 (ECF No. 101-1). Plaintiffs agree that the "undisputed facts establish that DirecTECH never installed any satellite dishes on plaintiffs' MDUs." Pls.' Mem. of Law in Opp'n to DirecTech's Mot. for Summ. J. ("Pls.' Opp'n") at 1 (ECF No. 104).

Notwithstanding, Plaintiffs argue that the "juridical link doctrine... recognizes [a] scenario[] where a putative class action plaintiff may be able to prosecute a class action against a defendant that did not injure the plaintiff:... instances in which all defendants are juridically related in a manner that suggests a single resolution of the dispute would be expeditious.'" Id. at 6 (quoting La Mar v. H & B Novelty & Loan Co., 489 F.2d 461, 465-66 (9th Cir. 1973)). DirecTech responds that "plaintiffs' arguments are misguided, focus on class certification issues, and ignore the requirement that a plaintiff who seeks to assert claims on behalf of a class against a defendant must have suffered an injury at the hands of that defendant." DirecTech's Reply Br. to Pls.' Opp'n to DirecTech's Mot. for Summ. J. ("DirecTech's Reply") at 1-2 (ECF No. 109).


Summary judgment is appropriate where "the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law." Fed.R.Civ.P. 56(a).


DirecTech moves for summary judgment, arguing that the named Plaintiffs lack standing to pursue claims against it individually or on behalf of a class. Plaintiffs do not contest DirecTech's factual assertions, but instead argue that a legal doctrine - the juridical link doctrine - provides them with standing and that issues of material fact exist with regard to whether the requirements of this route to standing are satisfied. The question of whether the juridical link doctrine offers Plaintiffs a way to satisfy the standing requirement is a purely legal one, making its determination appropriate at this stage. Further development of the facts urged by Plaintiffs would be unnecessary and futile.

"Article III of the Constitution confines the judicial power of federal courts to deciding actual Cases' or Controversies.' One essential aspect of this requirement is that any person invoking the power of a federal court must demonstrate standing to do so." Hollingsworth v. Perry, 133 S.Ct. 2652, 2661 (2013) (quoting U.S. Const. art. III, § 2). The Supreme Court has explained that "the irreducible constitutional minimum of standing contains three elements." Lujan v. Defenders of Wildlife, 504 U.S. 555, 560 (1992).

First, the plaintiff must have suffered an injury in fact-an invasion of a legally protected interest which is (a) concrete and particularized, and (b) actual or imminent, not conjectural or hypothetical. Second, there must be a causal connection between the injury and the conduct complained of - the injury has to be fairly... trace[able] to the challenged action of the defendant, and not... th[e] result [of] the independent action of some third party not before the court. Third, it must be likely, as opposed to merely speculative, that the injury will be redressed by a favorable decision.

Id. at 560-61 (internal citations and quotation marks omitted). "That a suit may be a class action... adds nothing to the question of standing, " because "even named plaintiffs who represent a class must allege and show that they personally have been injured, not that injury has been suffered by other, unidentified members of the class to which they belong and which they purport to represent.'" Lewis v. ...

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