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The filing challenges CHRA’s decision to install intrusive electronic monitoring equipment that collects and transmits granular data about presence, activity, and other in-home conditions. It argues the class action satisfies Rule 16(a) numerosity, commonality, typicality, adequacy, and adjudication requirements, and requests declaratory and injunctive relief, including deletion of collected data.",{"@graph":69,"@context":122},[70,84,105],{"@type":71,"itemListElement":72},"BreadcrumbList",[73,77,79,82],{"item":74,"name":75,"@type":76,"position":8},"https://docshare.wps.com","Home","ListItem",{"item":78,"name":9,"@type":76,"position":14},"https://docshare.wps.com/document/",{"item":80,"name":20,"@type":76,"position":81},"https://docshare.wps.com/document/exam/",3,{"item":83,"name":65,"@type":76,"position":19},"https://docshare.wps.com/document/plaintiffs-motion-for-class-certification-and-appointment-of-class-counsel-hearing-requested/322795/",{"url":83,"name":65,"@type":85,"image":86,"author":91,"headline":65,"publisher":94,"fileFormat":97,"inLanguage":63,"description":67,"dateModified":98,"datePublished":99,"encodingFormat":97,"isAccessibleForFree":100,"interactionStatistic":101},"DigitalDocument",{"url":87,"@type":88,"width":89,"height":90},"https://docshare.wps.com/thumbnails/plaintiffs-motion-for-class-certification-and-appointment-of-class-counsel-hearing-requested/322795.png","ImageObject",300,407,{"name":92,"@type":93},"Jasmine","Person",{"url":74,"name":95,"@type":96},"DocShare","Organization","application/pdf","2026-11-04","2026-09-21",true,{"@type":102,"interactionType":103,"userInteractionCount":39},"InteractionCounter",{"@type":104},"ViewAction",{"@type":106,"mainEntity":107},"FAQPage",[108,114,118],{"name":109,"@type":110,"acceptedAnswer":111},"What class is sought to be certified in this motion?","Question",{"text":112,"@type":113},"The motion seeks certification for all current and future CHRA tenants who have or will have Minut Monitor devices installed in their units.","Answer",{"name":115,"@type":110,"acceptedAnswer":116},"What is the main constitutional and privacy concern raised by the plaintiffs?",{"text":117,"@type":113},"The motion alleges the devices enable ongoing monitoring and transmission of granular information, and that the collection and retention of personal and private data constitutes an intrusive government incursion and unreasonable, warrantless, non-consensual searches.",{"name":119,"@type":110,"acceptedAnswer":120},"What relief do plaintiffs request if the class is certified?",{"text":121,"@type":113},"Plaintiffs request a declaratory judgment that CHRA violated tenants’ constitutional rights, an injunction preventing continued installation and maintenance of such devices, and an order requiring CHRA to delete all data collected by the Minut Monitors from tenants’ homes.","https://schema.org",{"og:url":83,"og:type":124,"og:title":65,"og:site_name":95,"og:description":67},"article",{"robots":126,"canonical":83},"index,follow",{"doc_id":128,"site_id":62},322795,1791039877,{"code":4,"msg":5,"data":131},{"doc_id":128,"user_id":132,"nickname":92,"user_avatar":133,"doc_module":4,"category_id":19,"category_name":20,"doc_title":65,"doc_description":67,"doc_content":134,"file_id":135,"file_url":136,"file_type":137,"file_size":138,"view_count":39,"is_deleted":4,"is_public":8,"is_downloadable":8,"audit_status":8,"page_count":139,"language":140,"language_code":63,"site_id":62,"html_lang":63,"table_of_contents":141,"faqs":142,"seo_title":143,"seo_description":67,"update_tm":144,"read_time":145,"preview_page_count":4},2336478487870,"https://ap-avatar.wpscdn.com/davatar_085a072bc5b1113ac321206ff7593b45","STATE OF NEW HAMPSHIRE  \nMERRIMACK, SS. SUPERIOR COURT  \nMark LaValley and Terri King, individually and on behalf of themselves and all others  \nsimilarly situated  \nv.  \nConcord Housing and Redevelopment Authority  \nNo.    \nPLAINTIFFS' MOTION FOR CLASS CERTIFICATION AND APPOINTMENT OF CLASS COUNSEL  \n(HEARING REQUESTED)  \nProposed class representatives Mark LaValley and Terri King move on behalf of themselves and all those similarly situated—and for the reasons detailed in their Complaint and the memorandum of law and declarations accompanying this Motion—to certify a class under Rule 16(a) of the New Hampshire Superior Court Rules.  \nIn support of this Motion, Plaintiffs state:  \n1. This Motion seeks certification with respect to Count I (Part I, Article 2-b of the New Hampshire Constitution) and Count II (Part I, Article 19 of the New Hampshire Constitution) of the following class: “All current and future tenants of Concord Housing and Redevelopment Authority (“CHRA”) who have or will have Minut Monitor devices installed in their units.”  \n2. This is a civil rights action challenging a local housing authority’s decision to install intrusive electronic monitoring equipment in hundreds of residential units. Those devices have the capacity to monitor and transmit, on an ongoing basis, granular information about presence and activity in the home, including by sensing motion  \nand measuring noise levels, number of iOS devices (and thus estimated number of people inside a unit), smoke, and other information. The collection of this data—which, pieced together, can reveal the intimate details of someone’s personal life—is an intrusive governmental incursion into a person’s private and personal affairs in their home.  \n3. This Motion for Class Certification and Appointment of Class Counsel is straightforward. Since the devices are installed across virtually all of CHRA’s units, a class action is the most efficient way to address these important constitutional issues.  \n4. The proposed class satisfies the prerequisites of Rule 16(a) .  \n5. The proposed class satisfies the numerosity requirements of Rule 16(a)(1) because the proposed class is so numerous that joinder of all members is impracticable. For example, CHRA has installed Minut Monitors in around 300 units representing around  \n500 tenants.  \n6. The class meets the commonality and predominance requirements of Rule 16(a)(2) . The members of the proposed class are subject to a common practice: the policy of the installation of Minut Monitors in their homes and continued surveillance via the monitoring of the private data collected from the devices. Further, the legal issues at stake because of that common practice will predominate over any individual issues of individual tenants.  \n7. The proposed class meets the typicality requirements of Rule 16(a)(3) because the claims of the proposed class representatives are typical of the claims of the class. The proposed class representatives and the proposed class are all persons who are subjected, or will be subjected, to the facially unconstitutional act of unreasonable, warrantless,  \nnon-consensual searches and government intrusion on their private data. Each class member who has had a Minut Monitor installed in their unit and had their personal and private information collected, faces the same injury based on the same government practice—namely, the installation ofthe Minut Monitor device and the non-consensual collection and retention of their personal and private data.  \n8. The adequacy requirements of Rule 16(a)(4) also are met. The proposed class representatives seek the same relief as the other members of the class, among other things,(i) a declaratory judgment that CHRA violated its tenants’ constitutional rights by installing the Minut Monitors and non-consensually collecting their personal and private information, and (ii) an injunction enjoining CHRA from continuing to install and maintain Minut Monitor devices that non-co","cbCaig6hrMvE75pK","https://ap.wps.com/l/cbCaig6hrMvE75pK","pdf",1201852,59,"English","# Plaintiffs' Motion for Class Certification and Appointment of Class Counsel\n## Motion basis and proposed class\n## Rule 16(a) requirements: numerosity, commonality, typicality, adequacy, adjudication","[{\"question\":\"What class is sought to be certified in this motion?\",\"answer\":\"The motion seeks certification for all current and future CHRA tenants who have or will have Minut Monitor devices installed in their units.\"},{\"question\":\"What is the main constitutional and privacy concern raised by the plaintiffs?\",\"answer\":\"The motion alleges the devices enable ongoing monitoring and transmission of granular information, and that the collection and retention of personal and private data constitutes an intrusive government incursion and unreasonable, warrantless, non-consensual searches.\"},{\"question\":\"What relief do plaintiffs request if the class is certified?\",\"answer\":\"Plaintiffs request a declaratory judgment that CHRA violated tenants’ constitutional rights, an injunction preventing continued installation and maintenance of such devices, and an order requiring CHRA to delete all data collected by the Minut Monitors from tenants’ homes.\"}]","Plaintiffs' Motion for Class Certification and Appointment of Class Counsel - Hearing Requested | PDF",1789963577,149]