Landman v. General Motors LLC
- Ronnie Abrams
- 1:24-cv-02238
- U.S. District Court · Southern District of New York
- 6
In Landman v. General Motors, Judge Abrams stayed the case pending the federal multidistrict-litigation panel’s transfer decision and adjourned the initial status conference.
The stay pauses Leah Landman’s case against General Motors LLC, OnStar LLC, and LexisNexis Risk Solutions Inc. until the Judicial Panel on Multidistrict Litigation rules on transfer and centralization. The initial status conference is also adjourned, and the parties must report the panel’s ruling within one week.
What happened
Leah Landman sued General Motors LLC, OnStar LLC, and LexisNexis Risk Solutions Inc. in a proposed class action concerning alleged collection and sharing of driving data. The parties jointly asked the court to pause the case while a federal panel considered whether to transfer and combine related cases.
The parties said 22 similar proposed class actions had been filed in eight federal districts. They argued that pausing this case would avoid duplicated work and inconsistent decisions while the panel considered centralizing the litigation. No responsive pleadings had been filed, and the case was still in its early stages.
Judge Ronnie Abrams granted the application. She stayed the action until the panel ruled, required the parties to file a joint letter within one week after that ruling explaining the result and proposing next steps if appropriate, and adjourned the initial status conference scheduled for June 7, 2024.
The detailed version
- Landman v. General Motors LLC · No. 1:24-cv-02238
- Ronnie Abrams
- May 23, 2024
Background
Leah Landman brought a proposed class action against General Motors LLC, OnStar LLC, and LexisNexis Risk Solutions Inc. The opinion text describes the action as involving allegations about the collection and sharing of certain driving data. The parties stated that 22 similar proposed class actions had been filed against the defendants in eight federal districts.
A plaintiff in one of the related cases had asked the Judicial Panel on Multidistrict Litigation (JPML) to transfer and centralize the cases under 28 U.S.C. § 1407. The JPML had scheduled a hearing for May 30, 2024. The defendants supported transfer and centralization but advocated for the Eastern District of Michigan rather than the Central District of California as the receiving court. The parties represented that Landman agreed to a stay and that plaintiffs in 20 of the 22 related actions had also agreed to stays.
Reasons for the Requested Stay
The parties argued that a stay would conserve judicial resources, avoid duplicative pretrial proceedings, and reduce the risk of inconsistent rulings. They noted that the related cases involved overlapping factual and legal questions, including possible motions requiring arbitration. They also argued that the case was at an early stage: no responsive pleadings had been filed and no discovery had occurred.
The defendants further argued that preparing a response to the complaint, including a possible motion to require arbitration, could waste time and resources if the JPML later centralized the cases and issued case-management orders governing the litigation.
Ruling
Judge Ronnie Abrams granted the application. The court stayed the action pending a ruling from the JPML. The parties must file a joint letter no later than one week after the JPML issues its ruling, informing the court of the result and, if appropriate, proposing next steps. The court also adjourned the initial status conference that had been scheduled for June 7, 2024.
The order addressed case management while the JPML considered transfer and centralization. It did not decide the merits of Landman’s claims or the defendants’ potential defenses.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.