Washington DC Class Action Lawsuits: CPPA, Settlements, Deadlines

Class action lawsuits in Washington, DC move through two court systems: DC Superior Court for cases built on District law, and the US District Court for the District of Columbia for federal claims and multi-state disputes. What makes DC distinctive is the Consumer Protection Procedures Act, a statute with unusually generous standing rules that has turned the District into one of the country’s more active jurisdictions for consumer, housing, and environmental class litigation. Recent settlements have returned tens of millions of dollars to residents, with more cases pending.

The CPPA Is Why DC Sees So Many of These Cases

The Consumer Protection Procedures Act, codified at DC Code § 28-3901 through § 28-3913, prohibits unfair and deceptive trade practices and lets a wide range of parties sue to enforce it. Individuals can bring claims. So can nonprofit organizations and public interest groups, and nonprofits do not need to show the organization itself was injured, only that specific consumers were harmed.¹ An organization can even buy a product specifically to test it for a lawsuit.

This “private attorneys general” structure means many CPPA cases bypass traditional class certification entirely. A nonprofit sues under § 28-3905(k)(1) on behalf of consumers generally, seeking injunctive relief, changes to business practices, and attorney fees rather than individual money damages.¹ When individual damages are sought, the CPPA allows statutory damages of $1,500 per violation.²

Plaintiffs strongly prefer DC Superior Court for these cases. Federal courts have often sent CPPA cases back to local court after finding that the per-consumer value of injunctive relief falls below the $75,000 federal jurisdictional threshold.

The reach of the statute keeps widening. In Earth Island Institute v. The Coca-Cola Company, the DC Court of Appeals ruled in August 2024 that even “aspirational” sustainability statements can be actionable if they would lead a reasonable consumer to believe the company is actually taking meaningful steps toward those goals when it is not. The court also held that a “mosaic” of corporate communications across websites, social media, and other platforms can be read together, and that whether statements amount to puffery is generally a jury question rather than one for dismissal.³

Recent Settlements and Where the Money Went

Live Nation and Ticketmaster: $9.9 Million

In April 2026, DC Attorney General Brian Schwalb announced a $9.9 million settlement with Live Nation over deceptive ticket pricing by its subsidiary Ticketmaster. The investigation found that from 2015 through mid-2025, the companies ran a bait-and-switch on prices, advertising a base number and adding mandatory fees at checkout. They also used countdown timers and pop-ups falsely warning that “tickets are selling fast” after just 60 seconds of user inactivity.⁴

Of the total, $8.9 million is earmarked for refunds to affected DC customers; the remaining $1 million goes to the District. Live Nation has committed to “all-in” pricing for DC events, showing the full cost including mandatory fees at the start of the purchase process.⁵ A formal claims process for consumer refunds was expected to be announced in the months following the settlement.

DC Health Link Data Breach: $1.45 Million

A March 2023 incident at DC Health Link, the District’s health insurance exchange, exposed data belonging to roughly 56,000 customers whose information was ultimately stolen and published, out of more than 170,000 individuals whose records a criminal entity reportedly attempted to sell on the dark web. The compromised information included Social Security numbers, dates of birth, health plan details, and employer information.⁶

The resulting class action, Lawless v. District of Columbia Health Benefit Exchange Authority, settled for $1.45 million. Final approval came on June 30, 2025, and payments to eligible class members issued on September 2, 2025. Those whose data was stolen and published could claim up to $10,000 for documented extraordinary losses like fraud or identity theft, or up to $2,500 for ordinary losses like credit monitoring costs. Class members who did not file loss-specific claims could receive a pro-rata cash payment from the remaining fund.⁶

Smith v. District of Columbia: $5.1 Million

A class action challenged DC’s gun control laws as unconstitutional for prohibiting people from carrying a pistol outside their home or business for self-defense. The class covered individuals arrested or prosecuted by DC’s Metropolitan Police Department for carrying without a license between May 2012 and October 2014. The settlement, approved in April 2024, totaled $5.1 million.⁷

DC Tax Refund Class Action

In American Philosophical Association v. District of Columbia, the DC Superior Court ruled in February 2024 that the District’s requirement that nonprofits maintain a local office to qualify for sales and hotel tax exemptions was unconstitutional under the Commerce Clause. Out-of-state 501(c)(3) organizations that paid DC sales or hotel occupancy taxes for events at District hotels from December 2016 forward are entitled to full refunds.⁸

Claims were due by June 6, 2025. As of mid-2026, the court still needed to rule on 16 disputed claims and a motion for attorney fees (capped at one-third of total approved claims) before distributing refunds. The District may appeal, which could delay payments by more than a year. The District also continued to enforce the law the court declared unconstitutional, and the court lacks authority to enjoin it, though additional claim periods may open for future events.⁸

Active Cases to Watch

RealPage and the Algorithmic Rent Case

In November 2023, the DC Attorney General filed what the office called the first government lawsuit against RealPage, Inc. and 14 of the District’s largest landlords, alleging they used RealPage’s algorithmic pricing software to coordinate and inflate rents on more than 50,000 apartment units across DC. The software, which processes confidential pricing data from competing landlords, is used to set rents on more than 30% of multifamily buildings in the District and roughly 60% of units in large buildings with 50 or more units.⁹

Settlements have come in waves. William C. Smith & Co. agreed in June 2025 to pay over $1 million and stop using the software. By June 2026, the AG had secured an additional $1.4 million from Avenue5 Residential and Bell Partners.¹⁰ Other defendants unsuccessfully moved to dismiss. The case continues against the remaining parties.

DC Water Sewage Spill

On January 19, 2026, a 72-inch section of the Potomac Interceptor, a major sewer line, collapsed near the Clara Barton Parkway and sent approximately 243 million gallons of raw sewage into the Potomac River. A class action was filed on March 6, 2026, in the US District Court for the District of Maryland on behalf of land and vessel owners along the river who suffered economic losses, including property contamination, business interruptions, and out-of-pocket cleaning costs.¹¹

The complaint alleges DC Water had documented knowledge of corrosion in the interceptor for over a decade before the collapse and failed to implement adequate safeguards or emergency plans. Attorneys estimate the class includes thousands of affected people.¹² In May 2026, plaintiffs moved to amend the complaint to expand the class geographically downriver to the Governor Harry W. Nice Memorial Bridge and to add claims drawing on government enforcement complaints filed in April 2026. The suit seeks monetary damages and injunctive relief, including expedited repairs and a comprehensive monitoring program. DC Water has declined to comment, citing ongoing litigation.

The Rules a DC Class Must Meet

In either court system, a class must clear four threshold requirements before it can proceed as a class action. The group must be large enough that individual lawsuits would be impractical (numerosity). The members must share common legal or factual questions (commonality). The named plaintiffs’ claims must be representative of the class (typicality). And those plaintiffs must be capable of fairly protecting the class’s interests (adequacy).¹³ The case must also fit one of three categories under Rule 23(b). The most common in DC is 23(b)(3), which requires that shared questions predominate over individual ones and that a class action is the best method for resolving the dispute.

DC Superior Court’s Rule 23-I adds local requirements. Complaints must include a dedicated section titled “Class Action Allegations” that spells out the class definition, its approximate size, the basis for the named plaintiff’s adequacy, and the common legal and factual questions.¹⁴ Plaintiffs must move for class certification within 90 days of filing. For cases seeking monetary damages under Rule 23(b)(3), the certification motion must include a detailed plan for notifying class members, including who pays for it. The rule specifically authorizes “mini-hearings” to resolve notice-cost disputes.

A 2023 DC Circuit ruling sharpened one piece of this framework. In Harris v. Medical Transportation Management, Inc., non-emergency medical drivers alleged wage theft that produced effective hourly rates as low as $4.00 to $9.00 under an $85 million government contract.¹⁵ The district court had certified “issue classes” under Rule 23(c)(4) to resolve threshold questions like joint employment, even after finding that broader certification failed the predominance test. The DC Circuit reversed, holding that issue classes must independently satisfy all of Rule 23’s prerequisites, and that plaintiffs cannot define an issue so narrowly that common questions “inevitably” predominate over themselves.¹⁶ The Supreme Court declined to review the decision in February 2024, and by April 2025 the case had progressed to partial summary judgment holding the company liable for the drivers’ unpaid wages.

Deadlines for Filing

Time limits for the claims that commonly underlie DC class actions come from DC Code § 12-301:

One year for assault, battery, false arrest, false imprisonment, malicious prosecution, defamation, and statutory penalties.
Three years for personal property recovery, property damage, simple contracts (express or implied), and any action without a separately prescribed limitation. This default captures most consumer protection claims.
Five years for property damage from toxic substances, measured from the date of discovery.¹⁷

These deadlines bind private plaintiffs. They do not apply to actions brought by the DC government itself, so the AG’s enforcement actions under the CPPA are not subject to the same time constraints.¹⁷

Changes Coming to the CPPA

The DC Council is poised to significantly strengthen the CPPA. The Enhancing Consumer Protection Procedures Amendment Act of 2026 passed the Council unanimously, 13-0. It creates a blanket ban on “drip pricing,” the practice of advertising a base price and then adding mandatory fees at checkout. It shifts civil penalties from discretionary to mandatory, with floors of $500 for a first offense and $1,000 for subsequent violations, and extends liability to vendors and payment processors who knowingly assist in deceptive practices.¹⁸

For private litigation, the law provides treble damages or $3,000 per violation, whichever is greater, plus attorney fees and punitive damages. Courts will be directed to interpret the CPPA in line with FTC and CFPB standards, reading them “most favorable to consumers.” The Act was awaiting mayoral action and a 60-day congressional review period as of mid-2026.¹⁸ If signed and allowed to take effect, it will raise the stakes on both ends of DC class and quasi-class litigation: higher per-violation damages for private plaintiffs, and mandatory penalty floors for the AG.

1
Shook, Hardy & Bacon. D.C. Courts and the CPPA
2
Joseph Greenwald & Laake. Firms File Class Action Against Walmart Alleging DC Consumer Protection Act Violations
3
DC Courts. Earth Island Institute v. The Coca-Cola Company, No. 22-CV-0895
4
WJLA. Live Nation to Pay Millions in Refunds to DC Ticket Buyers
5
DC Office of the Attorney General. Attorney General Schwalb Announces Live Nation Settlement
6
HIPAA Journal. District of Columbia Health Benefit Exchange Authority Data Breach Settlement
7
Smith v. DC Settlement. Settlement FAQ
8
DC Tax Refund Class Action. DC Tax Refund Class Action
9
DC Office of the Attorney General. Attorney General Schwalb Secures Over $1 Million in RealPage Settlement
10
Cohen Milstein. RealPage Antitrust Litigation
11
WTOP. Class Action Lawsuit Filed Against DC Water Following Potomac River Sewage Spill
12
Hagens Berman. DC Water Sewage Spill Class Action Lawsuit
13
Legal Information Institute. Federal Rules of Civil Procedure, Rule 23
14
DC Courts. Civil Rule 23-I: Class Actions Procedure
15
Cohen Milstein. Harris v. Medical Transportation Management, Inc.
16
Seton Hall Circuit Review. Rule 23 Class Certification Standards
17
D.C. Law Library. DC Code § 12-301 – Limitation of Time for Bringing Actions
18
Holland & Knight. No More Hidden Fees: DC Takes Aim at Drip Pricing