In re Anne Arundel Data Breach Litigation
1:25-cv-02274
D. MarylandAug 19, 2025Background
- Multiple class actions (21 total) were filed in Maryland federal court against Anne Arundel Dermatology, P.A. following a data breach that allegedly exposed patients' personal and health information.
- The Plaintiff, Correa, alleges the defendant delayed notification, did not explain the breach or its risks, and failed to offer adequate assistance.
- The lawsuits all allege similar harms (identity theft risks, privacy invasion, costs to mitigate harm) and seek overlapping relief.
- Correa moved to consolidate all related cases, appoint interim co-lead and liaison class counsel, and create an executive committee for the plaintiffs.
- The defendant did not respond to the motion, and no class member opposed consolidation.
- The court considered the appropriateness of consolidation and the appointment of leadership under Federal Rules 42(a) and 23(g).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Consolidation of Actions | All cases arise from the same data breach/public notice and have common factual/legal issues. | No response/argument made. | Granted—actions consolidated into a single proceeding. |
| Appointment of Co-Lead & Liaison Counsel | Proposed attorneys are well-qualified, experienced, and have investigated claims. | No response/argument made. | Granted—Klinger and Bean as co-leads; Mason as liaison. |
| Appointment of Executive Committee | An executive committee is necessary to manage the litigation. | No response/argument made. | Denied—no showing of necessity at this stage; may revisit. |
| Mootness of Other Consolidation Motions | N/A (other plaintiffs also moved to consolidate) | N/A | Other motion denied as moot due to this ruling. |
Key Cases Cited
- A/S J. Ludwig Mowinckles Rederi v. Tidewater Const. Co., 559 F.2d 928 (4th Cir. 1977) (district courts have broad discretion to consolidate cases)
- Arnold v. E. Air Lines, Inc., 681 F.2d 186 (4th Cir. 1982) (factors to consider for consolidation of cases)
