Seacor Holdings, Inc. v. Mason, 819 F.3d 190

Duwayne Mason, a Seacor crew member on the M/V SEACOR VANGUARD, sued Seacor for personal injuries allegedly sustained during Deepwater Horizon response/cleanup operations; his claims were consolidated into the MDL.
BP negotiated the Medical Benefits Settlement Agreement (B3 bundle) covering cleanup workers (Apr 20, 2010–Apr 16, 2012); the Agreement released claims against many parties, including Seacor; opt-out procedure required a signed written request by the class member.
The district court preliminarily approved the Agreement, set an opt-out deadline (ultimately Nov 1, 2012), and later granted final approval; the Agreement became effective Feb 12, 2014.
Before the opt-out deadline expired, Mason’s counsel moved to sever Mason’s claims from the MDL; the motion was not signed by Mason and counsel admits he did not discuss opting out with Mason before the deadline.
After the deadline, the court denied severance, Mason attempted other post-deadline steps (contacting claims administrator, motion to reconsider, extension request), and the district court granted Seacor summary judgment based on the settlement release; Mason appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Mason’s pre-deadline motion to sever constituted an effective informal opt-out	Mason: the motion to sever (filed before the opt-out deadline) manifested an intent to opt out	Seacor: the motion was not a signed, unequivocal opt-out and counsel did not have Mason’s express consent; allowing it would invite gamesmanship in a massive MDL	Court: abuse-of-discretion standard; district did not abuse discretion—motion to sever was not a valid informal opt-out (no client signature, counsel admitted no discussion, not unequivocal)
Whether notice of the Medical Benefits Settlement was constitutionally sufficient to bind Mason	Mason: inadequate notice — counsel did not receive electronic filings or the class notice and Mason lacked actual notice of inclusion/release of Jones Act claims	Seacor: counsel had actual notice and had investigated the Agreement; notice to counsel is imputable to client; published/class notice procedures were upheld	Court: notice was sufficient—Mason’s counsel had actual notice (imputed to Mason), satisfying due process; collateral attack on class judgment barred

In re Nissan Motor Corp. Antitrust Litig., 552 F.2d 1088 (5th Cir. 1977) (district courts possess broad discretion managing class actions)
In re Four Seasons Sec. Litig., 493 F.2d 1288 (10th Cir. 1974) (reasonable indication of intent to opt out can suffice)
In re Deepwater Horizon, 739 F.3d 790 (5th Cir. 2014) (district court approval of Medical Benefits Settlement and notice procedures affirmed)
Juris v. Inamed Corp., 685 F.3d 1294 (11th Cir. 2012) (absent class members may collaterally challenge judgment for lack of adequate notice)
Kemp v. Birmingham News Co., 608 F.2d 1049 (5th Cir. 1979) (class judgments generally bind members; due-process exception for inadequate notice)
Link v. Wabash R.R. Co., 370 U.S. 626 (U.S. 1962) (notice to attorney is imputed to client)
United Student Aid Funds, Inc. v. Espinosa, 559 U.S. 260 (U.S. 2010) (receipt of actual notice satisfies due process)
Ayers v. Thompson, 358 F.3d 356 (5th Cir. 2004) (abuse-of-discretion review for denial of opt-out in Rule 23(b)(2) context)