Justia Class Action Opinion Summaries

Defendant published a daily newspaper and contracted with individual carriers to deliver the paper. Named plaintiffs were four newspaper carriers for Defendant. Plaintiffs sued on behalf of a putative class of carriers, alleging that Defendant wrongly treated its carriers as independent contractors when they were employees as a matter of law. The trial court denied class certification, concluding that alleged individual variations in how carriers performed their work presented unmanageable individual issues that precluded certification. The court of appeals reversed in part, concluding that proof of employee status would not necessarily entail a host of individual inquiries. The Supreme Court affirmed, holding (1) whether a common law employer-employee relationship exists turns principally on the degree of a hirer’s right to control how the end result is achieved; (2) whether the hirer’s right to control can be shown on a classwide basis will depend on the extent to which individual variations in the hirer’s rights concerning each putative class member exist, and whether such variations, if any, are manageable; and (3) the trial court in this case erred in rejecting certification based not on differences in Defendant’s right to exercise control but on variations in how that right was exercised.View "Ayala v. Antelope Valley Newspapers, Inc." on Justia Law

An Employee filed a class action complaint against his Employer. The Employee, however, had entered into an arbitration agreement with his Employer that waived his right to class proceedings. The Employee also sought to bring a representative action under the Labor Code Private Attorneys General Act (PAGA). The Court of Appeal concluded that the entire arbitration agreement, which included a PAGA waiver, should be enforced. The Supreme Court reversed, holding, as regards the class action complaint, (1) a state law that restricts enforcement of the waiver of the right to class proceedings in arbitration agreements on grounds of public policy or unconscionability is preempted by the Federal Arbitration Act (FAA); but (2) the class action waiver at issue in this case was unlawful under the National Labor Relations Act, and the Employer waived its right to arbitrate. With regard to the PAGA action, the Court held (1) the FAA does not preempt a state law that prohibits waiver of PAGA representative actions in an employment contract; and (2) an arbitration agreement requiring an employee to give up the right to bring representative PAGA actions is contrary to public policy and unenforceable as a matter of state law.View "Iskanian v. CLS Transp. Los Angeles, LLC" on Justia Law

Loan officers for U.S. Bank National Association (USB) sued USB for unpaid overtime, asserting that they made been misclassified as exempt employees under the outside salesperson exemption. The trial court certified a class of plaintiffs and then determined the extent of USB’s liability to all class members by extrapolating from a random sample. The jury returned a verdict of approximately $15 million, resulting in an average recovery of more than $57,000 per person. The court of appeal reversed the trial court’s judgment and ordered the class decertified. The Supreme Court affirmed the court of appeal’s judgment in its entirety, holding that the trial court’s particular approach to sampling in this case was profoundly flawed and prevented USB from showing that some class members were entitled to no recovery. Remanded for a new retrial on both liability and restitution. View "Duran v. U.S. Bank Nat’l Ass’n" on Justia Law

Plaintiff was an hourly employee of Safeway, Inc. In 2010, in response to two writs of garnishment issued by the district court, Safeway deducted an excess of $29.64 from Plaintiff’s wages. Plaintiff subsequently filed a lawsuit against Safeway on behalf of herself and all other persons similarly situated, arguing that Safeway’s garnishment practice resulted in wrongfully excessive deductions. Ten days after the class action suit was filed, Safeway changed its payroll garnishment system to conform with the correct garnishment exemptions standards and tendered to Plaintiff the amounts that would have been paid to her had those standards been applied at the time. The circuit declined to certify the class and entered judgment in favor of Safeway. The court of special appeals affirmed. The Court of Appeals affirmed, holding (1) employees have a right of direct private action against their employer under Md. Code Ann. Lab. & Empl. 3-507.2 for deducting from the employee’s wage more than is lawfully allowed; and (2) the circuit court did not abuse its discretion under the circumstances of this case in denying class certification and in entering judgment for Safeway.View "Marshall v. Safeway, Inc." on Justia Law

In the 1990s, Defendants (Employers) created a sick-leave policy allowing employees to bank their sick leave in a continued illness bank (CIB). In 2002, Employers modified the terms of the CIB to create the CIB pay-out benefit, which allowed a capped amount of unused CIB hours to be paid to departing employees who completed twenty-five years or more of service. In 2008, Employers terminated the CIB pay-out benefit, and only employees who had reached twenty-five years of employment with Employers were entitled to their earned but unused CIB hours upon termination. Plaintiffs in this case represented employees who had not reached twenty-five years of service before the benefit ended. Plaintiffs brought a class action complaint against Employers. The district court granted summary judgment for Employers. The Supreme Court affirmed, holding that the district court did not err in determining that (1) Employers’ policies did not constitute a standardized group employment contract; (2) the CIB pay-out benefit was not deferred compensation or wages under the Montana Wage and Wage Protection Act; and (3) the covenant of good faith and fair dealing did not apply to Plaintiffs’ claims.View "Chipman v. Northwest Healthcare Corp." on Justia Law

Steve Sangwin, a State employee, was a qualified subscriber and beneficiary of the State of Montana Employee Benefits Plan (Plan), which was administered by Blue Cross and Blue Shield of Montana (BCBS). Steve's daughter, McKinley, was also a beneficiary under the Plan. This case arose after BCBS denied a preauthorization request for a medical procedure for McKinley on the grounds that the procedure was "experimental for research." Steve and his wife (collectively, the Sangwins) initiated this action by filing an amended complaint setting forth five counts, including a request for certification of a class action. The Sangwins defined class members as other beneficiaries of the Plan who had their employee benefits denied by the State based on the experimental exclusion for research in the past eight years. The district court granted the Sangwins' motion for class certification. The State appealed. The Supreme Court (1) affirmed the district court's order defining the class; but (2) reversed and remanded with respect to the question certified for class treatment, holding that the district court abused its discretion in specifying for class treatment the question of whether the State breached its contract of insurance with the plaintiffs.View "Sangwin v. State" on Justia Law

In consolidated appeals, defendants the Alabama Department of Corrections, various department officials, and Governor Robert Bentley, appealed in case no. 1111588, the trial court's determination limiting certain deductions from work-release earnings for inmates. In case no. 1120264, Jerry Mack Merritt (as sole representative of the plaintiff class) cross-appealed, raising numerous challenges to the trial court's final judgment. After its review, the Supreme Court dismissed the appeal in case no. 1120264 as untimely filed; in case no. 1111588, the Court reversed and remanded. The Court found that the department's interpretation of section 14-8-6 as permitting its collection of charges, which were not incident to the inmate's confinement, in excess of a 40% withholding cap established by that statute was both reasonable and consistent with the statutory language. View "Thomas v. Merritt" on Justia Law

Petitioners in these combined cases were former public employees who filed actions in the circuit court alleging violations of the West Virginia Human Rights Act (WVHRA). The circuit courts dismissed the complaints for Petitioners' failures to exhaust their administrative remedies, concluding that the exhaustion of administrative remedies available pursuant to the West Virginia Public Employees Grievance Procedure was a necessary precondition to the filing of a circuit court action. The Supreme Court reversed the rulings of the circuit courts, holding (1) a public employee, whose employment confers grievance rights before the West Virginia Public Employees Grievance Board, is not required to exhaust the administrative Grievance Procedure before initiating a complaint in the circuit court alleging violations of the WVHRA; and (2) the commencement of the Grievance Procedure does not preclude the institution of a circuit court action prior to exhaustion of the Grievance Procedure. Remanded.View "Weimer v. Sanders" on Justia Law

Appellants, approximately 750 employees, brought a class action against their employers (Employers), alleging five causes of action, including unlawful deductions made in violation of Minn. Stat. 181.79. The jury found Employers did not violate section 181.79. After the verdict, Appellants unsuccessfully requested judgment as a matter of law (JMOL) on their section 181.79 claim. The Supreme Court reversed, holding that Appellants were entitled to JMOL on their claim under section 181.79, as there was no legally sufficient basis for a reasonable jury to find that Employers did not make unlawful deductions from Appellants' wages in violation of section 181.79. Remanded with instructions to enter JMOL in favor of Appellants on liability for their section 181.79 claim.View "Karl v. Uptown Drink, LLC" on Justia Law

Under N.Y. Labor Law 196-d, an employer's "agent" may not retain tips. Two former Starbucks baristas brought a putative class action in the U.S. district court alleging that Starbucks' policy of allowing shift supervisors to receive distributions violated section 196-d. The district court concluded that the supervisors could participate in tip pools because their responsibilities did not render them Starbucks agents. Meanwhile, several former Starbucks assistant store managers filed a separate complaint asserting that assistant store managers should be entitled to participate in the tips pools. The U.S. district court concluded that section 196-d does not compel an employer to include any particular eligible employee in a tip pool. On appeal from both cases, the court of appeals certified two questions of law to the New York Court of Appeals, which answered by holding (1) an employee whose personal service to patrons is a principal part of his duties may participate in a tip allocation arrangement under section 196-d even if he possesses limited supervisory responsibilities, but an employee granted meaningful control over subordinates is not eligible to participate in a tip pool; and (2) Starbucks' decision to exclude assistant store managers from the tip pool was not contrary to section 196-d.View "Barenboim v. Starbucks Corp." on Justia Law