Miles v. America Online, Inc.
United States District Court for the Middle District of Florida
202 F.R.D. 297 (2001)
- Written by Sharon Feldman, JD
Facts
Marguerite Miles (plaintiff) filed a class-action complaint against America Online, Inc. (AOL) (defendant), alleging deceptive and unfair trade practices and fraud. Miles claimed AOL’s promotional campaign induced customers to subscribe to AOL’s internet-access services by stating that subscribers’ monthly fees would be $19.95 for unlimited internet access without disclosing that subscribers would also incur long-distance telephone charges. Miles sought class certification, arguing that AOL’s scheme presented common and predominant factual and legal issues and a class action was the only efficient way to address all complaints. Miles presented 4,700 letters from one of six of AOL’s call centers complaining about excessive long-distance bills, each seeking a modest amount. AOL argued that individualized issues of reliance and causation—necessary elements of Miles’s fraud and deception claims—made the lawsuit inappropriate for class representation.
Rule of Law
Issue
Holding and Reasoning (Moody, J.)
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