In 2007, the Seventh Circuit Court of Appeals awarded $30 million to roughly 1.7 million class members in the settlement of Carnegie vs.Household International and H&R Block. When the dust settled, $1.3 million dollars of unclaimed cy pres funds remained. Committed Temple Law alums Carolyn Lindheim ’87 and Steven Angstreich ’70, both attorneys with Weir Partners in Philadelphia, successfully petitioned to have those unclaimed funds assigned to the law school.
Carnegie was a class action suit on behalf of individuals who received a refund anticipation loan (RAL) from Beneficial National Bank through any H&R Block office between 1994 and 1996. The court found that defendants H&R Block and Beneficial National Bank made misrepresentations and charged undisclosed fees on tax RALs. Cy pres refers to the doctrine, applied especially to cases of charitable trusts or donations, that when the settlor or donor’s intended purpose becomes impossible, the court may substitute a more suitable purpose. In this case, argued attorneys Lindheim and Angstreich, the support of an educational program in consumer law at Temple would prove a worthy purpose for the unclaimed funds.
This cy pres award will enable Temple Law to offer a substantive course in consumer law and expanded student clinical and experiential opportunities in the areas of predatory lending, consumer bankruptcy, consumer credit, consumer fraud, mortgage foreclosure, and tax preparation assistance. The Law School will partner with legal agencies in the community where students will gain hands-on experience. Dean JoAnne Epps expressed her deep gratitude for this innovative contribution from Angstreich and Lindheim: “Their vision for the use of these funds will enhance opportunities for our students and faculty. It will also pay tribute to the work done by trial lawyers in representing individuals who have suffered from predatory lending practices. Carolyn Lindheim was a student in the first Evidence class I taught at Temple in 1985. It is very rewarding to see her success and to have the Law School benefit from the great work that she and Steve Angstreich did in this case."
At Weir, Angstreich litigates sophisticated and complex individual and class action cases. He has successfully handled numerous class actions in the fields of securities, antitrust, consumer fraud, toxic exposure, breach of fiduciary duty, waste and mismanagement, and land fraud. In addition, Angstreich serves as a mediator and arbitrator in complex alternative dispute resolution efforts and is active as an arbitrator on behalf of the U.S. District Court of New Jersey.
Lindheim engages in class action suits as well as complex individual commercial litigation. She has been involved with several cases tried to verdict, including class actions for breach of fiduciary duty, consumer fraud and toxic exposure. She has also litigated cases involving sophisticated contract and consumer fraud issues as well as professional malpractice.
Angstreich, Class of 1970Lindheim, Class of 1987