First Circuit Court of Appeals Vacates and Remands Buzzards Bay Oil Spill Case for Further Analysis
On February 23, 2010, the First Circuit Court of Appeals vacated and remanded the district court's denial of a claim for damages resulting from an oil spill in Buzzards Bay, finding that the district court had failed to "subject the parties' contentions to the plenary analysis that precedent requires." Gintis v. Bouchard Transportation Company, 2010 U.S. App. LEXIS 3644 at *1 (1st Cir. Feb. 23, 2010). Gintis arose from a 2003 oil spill involving a fuel barge owned and operated by the defendants, which caused damage to residential waterfront property along the bay. The plaintiff-appellant property owners moved in the district court to certify a class of similar situated individuals having property damaged in the spill. The district court denied the motion for class certification, finding that "common issues of law and fact do not predominate throughout the many potential claims of those who own, or own interests in, the bay shoreline." Id. at * 4.
In an opinion written by retired U.S. Supreme Court Justice David Souter (sitting by designation), the Court concluded that the district court had failed to exercise "informed discretion" in ruling on certification. Id. at * 9. The Court first noted the "rigorous analysis" that is required before a decision can be made concerning class certifications. In reviewing the district court's decision, the Court of Appeals found that the parties had presented considerable evidence of predominating common issues that required a more "searching evaluation" than that afforded by the district court. Id. at 5. Accordingly, the Court vacated and remanded the case for plenary consideration.