Judge in Opioid Cases Orders Disclosure of Litigation Financing
A federal judge overseeing the multidistrict litigation over the opioid epidemic has ordered lawyers to disclose all third-party financing arrangements in their cases.
May 07, 2018 at 06:28 PM
6 minute read
A federal judge overseeing the multidistrict litigation over the opioid epidemic has ordered lawyers to disclose all third-party financing arrangements in their cases.
On Monday, U.S. District Judge Dan Polster of the Northern District of Ohio, who is overseeing hundreds of lawsuits brought by governmental entities against the manufacturers and distributors of opioids, ordered lawyers working on contingency to submit a letter identifying the financing for in camera review. He also ordered each lawyer and lender to submit sworn affirmations stating that the financing does not create any conflicts of interest, “undermine counsel's obligation of vigorous advocacy,” affect the lawyer's judgment, give the lender “control over litigation strategy or settlement decisions,” or affect the litigant's control of the settlement.
“It has come to the court's attention that there may be attorneys who represent parties in cases transferred to this MDL court who have obtained (or are contemplating) third-party contingent litigation financing in connection with those MDL cases,” wrote Polster. “By 'third-party contingent litigation financing,' the court refers to any agreement under which any person, other than an attorney permitted to charge a contingent fee representing a party, has a right to receive compensation that is contingent on and sourced from any proceeds of an MDL case, by settlement, judgment, or otherwise.”
He added that he would sanction attorneys or lenders who lied about their arrangements, and he would consider unenforceable any financial arrangements that did not comply with the order.
Plaintiffs lawyers spearheading the opioid MDL said the order came as no surprise.
“It's not at all surprising as it is common practice in complex MDLs for the MDL judge to ensure that no third party of any kind has influence over attorney judgment,” wrote co-lead plaintiffs counsel Paul Hanly, of Simmons Hanly Conroy in New York. “Not at all unwelcome.”
Joseph Rice of Motley Rice, another co-lead counsel, issued a statement on behalf of the plaintiffs executive committee: “It is not unusual for an MDL judge to request such information concerning third-party financing by individual attorneys, and the PEC is in agreement that to the extent such arrangements exist, those attorneys should provide the requested information to Judge Polster.”
But many experts in litigation financing said such an order, while not unheard of, is rare.
“This was the first I've seen where a judge in an MDL, not a class action, has issued this type of order,” said Charles Agee of Westfleet Advisors in Nashville, Tennessee.
His litigation financing firm's research found about 30 orders in individual cases involving outside funding disclosures. Most of those orders have either asked for the funding agreement or allowed limited discovery on the arrangements—all on a heavily redacted basis.
“I don't think I've ever seen an order, in an individual case, where the judge is asking for a co-signed letter with the funder and attorney,” he said.
Anthony Sebok, a professor at Benjamin N. Cardozo School of Law at Yeshiva University in New York, who consults with Burford Capital, agreed.
“This is the first MDL order I've seen like this,” he said. But, he noted, it's one that litigation financiers can live with because the disclosure requirements are “of an extremely minimal nature.”
Travis Lenkner of Chicago's Keller Lenkner, declined to say whether third-party financing was behind five class actions his firm filed last week over the opioid epidemic. But Lenkner, who co-founded Gerchen Keller Capital, now part of Burford Capital, said the order “strikes a good balance.”
In particular, Polster's order barred all discovery about outside financing “absent extraordinary circumstances.” The judge, once exclusively focused on obtaining a global settlement, allowed some discovery to go forward last month.
The order comes amid a growing effort among corporate groups to force disclosures of outside funding in contingency fee cases. The U.S. Chamber of Commerce's Institute for Legal Reform and other business groups have called on Congress and the Judicial Conference Advisory Committee on Rules of Civil Procedure to consider a rule mandating such disclosures in class actions and in multidistrict litigation. The U.S. District Court for the Northern District of California adopted a rule last year in class actions, and Wisconsin's Legislature passed a law this year requiring such disclosures in state court cases.
Burford CEO Christopher Bogart, noting those efforts, called the order a “welcome example of litigation finance disclosure done right” and “a model for other judges to follow.” In particular, he praised the order's focus on confidentiality and kibosh on discovery.
“While it's clear that there is some desire in some corners of the American legal system for there to be disclosure of litigation finance arrangements in certain U.S. court proceedings, especially those involving multiple claimants such as class actions and MDLs, current calls for disclosure tend to be sponsored by special interests seeking tactical advantage and framed in a discriminatory way,” he wrote.
A Burford spokeswoman declined to comment on whether the funder was involved in the opioid litigation.
Defense bar groups said Polster's order did not go far enough.
“We are very pleased that this court—like others—recognized the critical importance of disclosure of litigation funding. However, we believe that there should be full disclosure of the funding agreement to all parties in a case, just as defendants are required to disclose and provide insurance agreements to all parties,” wrote Lisa Rickard, president of the Chamber's Institute for Legal Reform. “Full disclosure is particularly important in this litigation where many plaintiffs are governmental entities that shouldn't be secretly signing over potential recoveries to hedge funds.”
Alex Dahl, general counsel of Lawyers for Civil Justice, which has pushed for the change in the civil rules, said the order demonstrates why the issue shouldn't be left up to the courts.
“This ruling acknowledges the serious problems that can result from third-party litigation funding (TPLF), including conflicts of interest, professional responsibility issues and questions about control,” he wrote. “But the ruling fails to provide transparency to the parties in the case, which is key. It also illuminates the need for uniform rules to replace the ad hoc way in which some MDL courts are making up new procedures on a case-by-case basis.”
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View All'Absurd Costs'?: Visa Faces Antitrust Class-Action Surge Following DOJ Complaint
3 minute read'Systemic and Pervasive'?: DiCello Levitt Alleges WWE Child Sexual Abuse Scandal
3 minute readThe 2024 NLJ Awards: Professional Excellence—Appellate Hot List
4th Circuit Revives Workplace Retaliation Lawsuit Against Biden's HHS Secretary
3 minute readTrending Stories
- 1Dog Gone It, Target: Provider of Retailer's Mascot Dog Sues Over Contract Cancellation
- 2Lululemon Faces Legal Fire Over Its DEI Program After Bias Complaints Surface
- 3Plaintiff Gets $500K Policy Limit Without Surgery
- 4Philadelphia Bar Association Executive Director Announces Retirement
- 5SEC Chair Gary Gensler to Resign on Trump's Inauguration Day
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250