Staniec vs. City of Philadelphia
(A Guide to the Case)
In March of 2023, the class action litigation team at Saltz Mongeluzzi Bendesky P.C. obtained an opinion reversing a trial judge’s initial decision that denied class action certification in Staniec vs. City of Philadelphia—it is a case centered around the lack of refunds provided to participants of a race that was canceled during the COVID-19 pandemic.
The appellate court determined that the trial court incorrectly ruled that the named plaintiff (Monica Staniec) failed to establish a prima facie case for class action certification. Within this article, our Philadelphia class action litigation attorney provides a comprehensive guide to the key things that you should know about the case of Staniec vs. City of Philadelphia.
Background: The City of Philadelphia Organizes and Operates the Broad Street Run
The Broad Street Run is Philadelphia’s iconic 10-mile road race that is held annually and typically draws tens of thousands of participants. Established in 1980, the race is known for its fast, flat course that takes runners through a direct route down the city’s primary north-south thoroughfare, Broad Street. It runs every year. Indeed, the next annual Broad Street Run is scheduled for an as-of-yet undetermined date in April of 2024.
The 2020 Broad Street Run Was Initially
Rescheduled From May to October
In 2020, the Broad Street Run was disrupted by the COVID-19 pandemic. The disruption eventually led to a class action lawsuit being filed against the city (Staniec vs. City of Philadelphia). The race was initially scheduled to take place on May 3rd, 2020. As a consequence of the COVID-19 pandemic, which hit the United States hard in March 2020, race organizers decided to reschedule that year’s Broad Street Run for October. Notably, more than 40,000 people had already registered—and paid the fees—for the event.
Philadelphia Eventually Transitioned the Event to a “Virtual Race” Citing COVID-19
On June 14th, 2020, the City of Philadelphia announced that there would be no in-person Broad Street Run in 2020. The October race was “canceled.” Organizers told the runners that they would instead be transitioned to a so-called “virtual race.” In effect, the virtual event was a self-timed ten-mile race that runners could complete at any time they wanted. They would then be able to upload their time. It was not and, in fact, could not be on Broad Street because the course was not set up and traffic was not being redirected.
The City Refused to Offer Refunds to the Runners (More than 40,000 People Paid $57)
According to official records that have been submitted to the court, more than 40,000 people were registered for the Broad Street Run in 2020. The cost for an individual registration was $57. When the City of Philadelphia announced that participants were being transitioned to a virtual event, it also stated clearly that absolutely no refunds were going to be issued. Indeed, the City of Philadelphia refused to give any of the runners their money back. Instead, runners were offered the following three things in addition to the ability to run a self-timed, virtual race:
- The t-shirt for the 2020 Broad Street Run;
- A finisher’s medal (issued to all participants, regardless of virtual race results); and
- The right to register for the 2021 Broad Street Run at a 20 percent discount.
A Proposed Class Action Lawsuit Was Filed By One of the Affected Participants
In August 2020, Monica Staniec filed a proposed class action lawsuit on behalf of herself and similarly situated runners who had their race canceled and were denied any opportunity to claim a refund by the City of Philadelphia. The class action claim was filed with a trial court. Among other things, the class action lawsuit filed by Ms. Staniec accuses the city of:
- Breach of contract;
- Unilaterally altering the terms of a contract; and
- Unjust enrichment.
Philadelphia Filed a Motion to Dismiss, the Trial Court Granted It
In response to the lawsuit, the City of Philadelphia filed a motion to dismiss. Specifically, the City moved for the dismissal of the lawsuit on the grounds that class action certification was inappropriate. In October of 2021, the trial court granted Philadelphia’s motion to dismiss. Notably, the trial court wrote that the plaintiff did not provide sufficient evidence to “satisfy the commonality, typicality, and predominance requirements for certifying a class.” An appeal of the motion to dismiss was filed on behalf of Ms. Staniec and similarly situated potential class members.
The Appeal: Trial Court Erred in Denying Class Action Certification
On March 17th, 2023, the Pennsylvania Commonwealth Court overturned the trial court’s decision. The appellate court determined that the trial court erred in denying class action certification. The court found that the plaintiff met all of the required elements to qualify for class action certification in Pennsylvania. The court analyzed the following three points in detail:
Commonality and Predominance: For a class action to be certified in Pennsylvania, there must be common questions of law and/or common questions of fact among the proposed members. You will often hear this referred to as the commonality requirement. State law also requires “predominance”—meaning the importance of the common questions of law/facts must outweigh individual member concerns. The appellate court emphasized that whether or not the City of Philadelphia breached a contract and/or unjustly enriched itself by denying refunds is a common and predominant question for all 40,000+ runners in the case.
Typicality: Another required element to qualify for class action certification in Pennsylvania is “typicality.” It is a requirement that ensures that the class representative’s stance on common issues aligns with the absent class members. Typicality is established when the representative’s claims result from the same actions and employ similar legal theories as other potential class members. The trial court determined that this element was not met as the potential damages could vary for different class members. However, on appeal, judges found that such differences should not hinder a class action. The appellate court found that Ms. Staniec claim(s) were typical because they arose from the same course of conduct as other potential class members.
Fair and Efficient Method: Finally, a class action can only be certified in Pennsylvania if it is deemed a fair and efficient method of adjudication. In the opinion of the appellate court, the trial court mistakenly found Staniec did not meet the criteria for commonality, predominance, and typicality for class certification. As a consequence, the trial court never made a determination as to whether or not a class action lawsuit would be a fair and efficient method of adjudication for this particular case.
Based on its review of the facts and circumstances, the Pennsylvania Commonwealth Court determined that the trial court improperly granted the City of Philadelphia’s motion to dismiss the class action lawsuit. The appellate court vacated the decision and remanded the matter back to the trial court to apply the court’s legal standard on commonality, predominance, and typicality and to determine if a class action would be a fair and efficient method of adjudication.