SMITH v. APRIA HEALTHCARE LLC
1:23-cv-01003
S.D. Ind.Jun 5, 2025Background
- Plaintiffs sued Apria Healthcare LLC in a class action following a data breach that exposed sensitive personal, medical, insurance, and financial information of Apria’s patients (over 1.8 million individuals) in 2019 and 2021.
- Plaintiffs allege Apria delayed disclosure of the breach until May 2023, nearly two years after becoming aware.
- Plaintiffs sought preliminary court approval of a settlement agreement that would resolve their and the class members' claims.
- The class consists of all individuals notified by Apria that their information may have been compromised, excluding certain persons (e.g., judges, Apria itself, those opting out).
- Apria agreed to a $6,375,000 cash settlement fund, reimbursement for out-of-pocket losses up to $2,000 per person, and substantial changes to its security practices. Settlement administration would be handled by Kroll.
- Plaintiffs moved for preliminary approval of class certification, appointment of class representatives and counsel, notice to the class, and preliminary appointment of a settlement administrator. Apria did not oppose.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Preliminary Class Certification under Rule 23 | All Rule 23 prerequisites and settlement requirements met | Not opposed | Certification granted for settlement purposes |
| Adequacy and Fairness of Settlement | Settlement is fair, reasonable, and adequate | Not opposed | Settlement preliminarily approved |
| Adequacy of Class Representation and Counsel | Plaintiffs and counsel are adequate per Rule 23(a)(4) | Not opposed | Representation/counsel preliminarily adequate |
| Notice to Class | Proposed notice plan meets Rule 23 requirements | Not opposed | Notice plan preliminarily approved |
Key Cases Cited
- Gen. Tel. Co. of the S.W. v. Falcon, 457 U.S. 147 (numerosity, commonality, typicality, adequacy for class certification under Rule 23)
- Amchem Prods. v. Windsor, 521 U.S. 591 (heightened scrutiny of settlement class certification)
- Smith v. Sprint Communs. Co., L.P., 387 F.3d 612 (settlement relevance to certification analysis)
- Santiago v. City of Chicago, 19 F.4th 1010 (Rule 23 requirements and balancing)
- Beaton v. SpeedyPC Software, 907 F.3d 1018 (commonality requirement for class certification)
- Mulvania v. Sheriff of Rock Island Cnty., 850 F.3d 849 (numerosity standard for class certification)