Basile v. H & R Block, Inc.
52 A.3d 1202
| Pa. | 2012Background
- Basile sued H&R Block entities and Mellon Bank in 1993, alleging fiduciary breaches in the Rapid Refund program (refund anticipation loans).
- In 1997, the common pleas court certified a class of about 600,000 customers for a fiduciary-duty claim; summary judgment later favored Block on a lack of fiduciary relationship.
- The Superior Court in 2001 held prima facie evidence supported a confidential relationship, focusing on class-wide considerations and overmastering influence.
- In 2003 the common pleas court decertified the class for lack of predominance due to individualized trust inquiries.
- The Superior Court reversed in 2010, remanding for further proceedings, and this Court granted review to address the correctness of that ruling.
- The Court ultimately reinstates the common pleas’ decertification, holding the confidential-relationship element is not amenable to class treatment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the confidential-relationship element amenable to class treatment? | Basile argues class-wide proof suffices. | Block argues individualized inquiry required. | Decertification proper; not amenable to class treatment. |
| May summary-judgment style evidence govern class certification decisions? | Evidence should be evaluated classwide on its probative value. | Different standards apply; trial-focused factfinding required. | Do not conflate summary-judgment and class-certification review. |
| Can overmastering-influence proof be established on a class-wide basis? | Block documents show uniform influence on class members. | Impact varies by individual characteristics; not uniform. | No class-wide, homogeneous impact proven. |
| What level of deference should appellate review give to the trial court's certification decision? | Superior Court properly reviewed factual predicates for class treatment. | Trial court’s discretionary decertification should be upheld absent error. | Lower court’s discretion was not abused; decertification can be sustained. |
Key Cases Cited
- Basile v. H & R Block, Inc., 777 A.2d 95 (Pa.Super.2001) (confidential relationship proof; class action viability)
- Basile v. H & R Block, Inc., 11 A.3d 992 (Pa. Super. 2010) (reaffirming confidential-relationship analysis; class-wide proof insufficient)
- Leedom v. Palmer, 274 Pa. 22, 117 A. 410 (1922) (confidential relationship defined by overmastering influence or trust)
- Estate of Scott, 455 Pa. 429, 316 A.2d 885 (1974) (confidential relationship framework; relational focus)
- Liss & Marion P.C. v. Recordex Acquisition Corp., 603 Pa. 198, 217-18, 983 A.2d 652, 663 (2009) (common question of fact; substantially the same proof needed)
- Wilson v. El-Daief, 600 Pa. 161, 964 A.2d 354 (2009) (summary judgment standards; factual proffers differ from class cert.)