Justia Class Action Opinion SummariesArticles Posted in Employment Law
Machado v. System4 LLC
Plaintiffs were individuals who entered into contracts with Defendants for the provision of janitorial services to third-party customers. Plaintiffs filed this putative class action, alleging that Defendants violated the Massachusetts Wage Act. Defendants moved to stay the court proceedings pending arbitration according to the terms of the arbitration clause contained in the parties' franchise agreements. The superior court denied the motion, concluding that the arbitration clause was unenforceable as set forth in Feeny v. Dell Inc. (Feeney I). After the United States Supreme Court decided AT&T Mobility LLC v. Concepcion, Defendants sought appellate review, which the Supreme Court granted. The Supreme Court reversed the order invalidating the arbitration in light of its interpretation of Conception and its impact on Feeney I, as set forth in Feeney II, holding (1) Massachusetts public policy in favor of class proceedings in certain contexts may no longer serve, in and of itself, as grounds to invalidate a class waiver in an arbitration agreement; and (2) in this case, Plaintiffs failed to demonstrate they lacked a practical means to pursue their claims on an individual basis.View "Machado v. System4 LLC" on Justia Law
Chipman v. Nw. Healthcare Corp.
Plaintiffs were employees of Defendant Kalispell Regional Medical Center (KRMC). Defendant Northwest Healthcare Corporation (NWHC) was the parent corporation of the remaining defendant entities. This case arose out of a dispute over the discontinuation of a sick leave buy-back program. Defendants appealed the order of the district court granting Plaintiffs' motion for class certification. The Supreme Court affirmed, holding (1) the district court properly determined that the named Plaintiffs had standing to bring claims against defendants they did not directly work for because the juridically linked Defendants were operating under a common scheme; and (2) the district court did not abuse its discretion in certifying the class under Mont. R. Civ. P. 23(a) and (b). View "Chipman v. Nw. Healthcare Corp." on Justia Law
Wilson v. Thomas
The Alabama Department of Corrections ("ADOC"), the Alabama Corrections Institution Finance Authority ("ACIFA"), and Kim Thomas, in his official capacities as the commissioner of ADOC and as ex officio vice president of ACIFA, petitioned the Supreme Court for a writ of mandamus to direct the Montgomery Circuit Court to vacate its May 2012 order denying their motion seeking a partial summary judgment and requested the court enter a new order granting their motion. In 2010, Albert Wilson, Rufus Barnes, Joseph Danzey, Bryan Gavins, and Donald Simmons, all of whom were employed by ADOC as correctional officers, sued ADOC and its then commissioner Richard Allen alleging that ADOC was violating its own regulations and state law in the manner in which it: (1) compensated correctional officers for overtime; (2) restricted the way correctional officers were allowed to use earned leave; and (3) paid correctional officers the daily subsistence allowance provided by law. The plaintiffs also sought class certification on behalf of all other similarly situated correctional officers employed by ADOC and requested injunctive relief, as well as money damages, to include backpay with interest, punitive damages, and litigation costs and expenses, including attorney fees. Because ADOC and Thomas, in his official capacity as commissioner of ADOC, were entitled to State immunity on those claims, the Court granted the petition as to ADOC and Thomas, in his capacity as commissioner of ADOC, and issued the writ. However, ACIFA and Thomas, in his official capacity as vice president of ACIFA, did not argue that they were entitled to State immunity on the claims asserted against them; rather, they argued that those claims lacked merit. That argument presented an insufficient basis upon which to issue a writ of mandamus, and the Supreme Court therefore denied the petition with regard to the those claims because ACIFA and Thomas had an adequate remedy on appeal. View "Wilson v. Thomas " on Justia Law
Perez-Farias v. Global Horizons, Inc.
Three certified questions came before the court from the Ninth Circuit Court of Appeals concerning application of the farm labor contractors act (FLCA), chapter 19.30 RCW. The primary question asked whether a trial court, if awarding statutory damages under the civil remedies provision of the FLCA must award $500 per plaintiff per violation. Upon review, the Washington Supreme Court answered in the affirmative. The second question asked whether requiring a trial court to award $500 per plaintiff per violation violated due process or public policy; the Court answered in the negative, expressly limiting its analysis and holding on this question to state due process principles and statutes. The third question asked whether the FLCA provided for awarding statutory damages to persons who have not been shown to have been aggrieved by a particular violation. "Because our standing jurisprudence tracks that of the United States Supreme Court, we leave to the Ninth Circuit to answer this question based on its standing jurisprudence and the standing jurisprudence of the Supreme Court." View "Perez-Farias v. Global Horizons, Inc." on Justia Law