Justia Class Action Opinion Summaries

The plaintiffs in this case were employees at three separate carpet manufacturing facilities operated by defendant Royalty Carpet Mills, Inc. (Royalty), also known as Royalty Carpet Mills, LLC. They alleged representative claims under the Private Attorneys General Act (PAGA), and class claims primarily based on purported meal and rest period violations. They sought premium pay under Labor Code section 226.7 for these violations and asserted derivative claims for waiting time and wage statement penalties, among others. The trial court initially certified two classes: one for employees that worked at a facility in Porterville (the Porterville class) and another for employees that worked in two separate facilities in Orange County (the Dyer/Derian class). Following the presentation of evidence at trial, the court decertified the Dyer/Derian class and entered judgment. The results were mixed and both sides appealed. The Court of Appeal agreed with three of Plaintiffs' six contentions: the court erred in failing to apply the relation back doctrine, in decertifying the Dyer/Derian class, and dismissing the PAGA claims as unmanageable. The case was remanded for further proceedings. View "Estrada v. Royalty Carpet Mills, Inc." on Justia Law

The case arose when four Micron Technology, Inc. employees filed a class action complaint against Micron in 2019, asserting violations of the Idaho Wage Claim Act. At the time, Micron had in place a compensation plan called the Incentive Pay Plan (IPP), in which eligible employees could earn yearly bonuses based on a number of performance metrics. The Employees alleged that the bonuses they received on November 23, 2018, for Micron’s 2018 fiscal year should have been greater. Micron moved for summary judgment, arguing that the Employees’ complaint was time-barred by Idaho Code section 45-614. Micron argued that section 45-614’s six-month statute of limitations applied to the Employees’ complaint because they sought “additional wages,” as opposed to “unpaid wages.” The district court granted Micron’s motion for summary judgment. The Employees timely appealed, arguing that the two-year statute of limitations applied. Finding no reversible error, the Idaho Supreme Court affirmed the district court's decision. View "Manning v. Micron Technology, Inc." on Justia Law

Simpson unsuccessfully applied to work as a Correctional Officer at the Cook County Department of Corrections four times in 2014-2017. Simpson believed the hiring practices underlying those rejections violated his rights—and those of other unsuccessful Black applicants—under Title VII of the Civil Rights Act, 42 U.S.C. 2000e-2(a)(1). Invoking disparate treatment and disparate impact theories, Simpson’s class action complaint alleged that, through the use of a five-step hiring process for correctional officers, the Department both intended to discriminate against Black applicants and succeeded in producing that result. The district court denied Simpson’s motion for class certification, finding that none of his proposed classes—a general class of all unsuccessful applicants and five subclasses of candidates dismissed at each step of the hiring process—satisfied Rule 23(a)(2)’s requirement that they present “questions of law or fact common to the class.”The Seventh Circuit vacated. The district court’s analysis apparently merged Simpson’s disparate impact claims with his disparate treatment claims for intentional discrimination. While disparate treatment claims may require a more searching commonality inquiry, disparate impact claims most often will not: the common questions are whether the challenged policy has in fact disparately impacted the plaintiff class and, if so, whether that disparate impact is justified by business necessity. The court did not clearly delineate its reasoning for declining to certify three of Simpson’s disparate impact subclasses. View "Simpson v. Dart" on Justia Law

Plaintiff Jason Cirrincione appealed an order denying class certification in a wage-and-hour action he filed against his former employer, defendant American Scissor Lift, Inc. (ASL). On appeal to the Court of Appeal, plaintiff argued reversal was required for a number reasons, including that the trial court’s ruling rested upon improper merits determinations and incorrect assumptions. Finding no reversible error, the Court of Appeal affirmed the denial of class certification. View "Cirrincione v. American Scissor Lift" on Justia Law

The Court of Appeal affirmed an order denying certification of a class of persons who worked without pay for American Film Institute (AFI). The court concluded that the trial court acted within its discretion in finding that common issues would not predominate over individual ones. In this case, the putative class members who expected no compensation were not employees under California law; the class that plaintiff moved to certify is broad enough to include persons who expected to be paid; and thus, if the case were to proceed as a class action, the trier of fact would need to decide whether each class member expected to be paid or was in fact a volunteer. View "Woods v. American Film Institute" on Justia Law

Isabel Garibay appealed a trial court's confirmation of a class action settlement reached between Josue Uribe and Crown Building Maintenance Company (Crown). Uribe sued Crown as an individual regarding alleged Labor Code violations for failure to reimburse him for the cost of uniform cleaning and required footwear as a day porter doing janitorial-type work. Uribe’s suit also included a cause of action in a representative capacity for civil penalties and injunctive relief under the Labor Code Private Attorneys General Act of 2004 (PAGA). The parties reached a settlement conditioned on Uribe filing an amended complaint converting his lawsuit into a class action on his Labor Code claims and including unreimbursed employee cell phone usage costs as an additional basis for both his Labor Code and PAGA causes of action. Garibay, an unnamed member of the class once it was formed, had earlier filed in the Alameda County Superior Court a putative class action asserting Labor Code claims for unreimbursed cell phone use by Crown employees, together with a representative PAGA cause of action on that basis. When Uribe and Crown sought preliminary approval of their agreement to settle Uribe’s lawsuit on a class-wide basis, the trial court authorized Garibay to intervene as a named party in the lawsuit to oppose the settlement. The trial court later granted Uribe’s motion for preliminary approval of the settlement, and then Crown and Uribe’s joint motion for final approval. Meanwhile, the Judicial Council had referred Crown’s petition to coordinate Uribe’s and Garibay’s lawsuits to the presiding judge of the Alameda court to appoint a judge to hear the petition; that appointment remained pending at the time the judgment in Orange County was entered. After the parties advised the Alameda court no stay had been entered in the coordination proceedings, the court subsequently entered judgment. Garibay challenged the settlement after the trial court declined to rule on both Crown’s motion to dismiss Garibay’s complaint in intervention and Garibay’s motion to vacate the judgment. The Court of Appeal found Uribe's PAGA notice did not encompass a claim for unreimbursed cell phone expenses, making the notice was inadequate to support Uribe’s PAGA cause of action on that theory in his lawsuit. And because Uribe and Crown’s agreement did not allow for severance of nonviable settlement terms, judicial approval of a settlement that included Uribe’s PAGA cause of action could not survive review. The Court therefore reversed the judgment. View "Uribe v. Crown Building Maintenance Co." on Justia Law

Railey clocked in and out of work at the Sunset Food Mart by placing her hand on a biometric scanner. She brought a class action in state court in 2019 alleging violations of the Illinois Biometric Information Privacy Act. Two years into litigation, Sunset removed the case to federal court, alleging that Railey’s claims were completely preempted by the Labor Management Relations Act. Sunset explained the timing of the removal by pointing to an interrogatory response it received from Railey in October 2020 in which she confirmed her membership in a labor union.The district court found Sunset’s removal untimely. Citing the Class Action Fairness Act, 28 U.S.C. 1453(c)(1), the Seventh Circuit affirmed the remand to state court. A Class Action Fairness Act exception for “home-state controversies” directs that district courts “shall decline to exercise jurisdiction” over a class action in which “two-thirds or more of the members of all proposed plaintiff classes in the aggregate, and the primary defendants, are citizens of the State in which the action was originally filed,” 28 U.S.C. 1332(d)(4)(B). Railey brought a putative class action on behalf of Illinois citizens against a small Illinois grocery chain under Illinois law. Sunset missed its preemption-based removal window. View "Railey v. Sunset Food Mart, Inc." on Justia Law

Current and former mortgage loan officers claim that Citizens Bank forced them—and more than a thousand of their colleagues—to work over 40 hours a week without paying them the overtime they were due under state and federal law. They filed a collective action under the Fair Labor Standards Act (FLSA), 29 U.S.C. 207, and parallel state-law claims that they wished to pursue as a class action under FRCP 23. The district court scheduled a trial on the primary factual issue in the FLSA opt-in collective action but left unresolved whether it would certify a class for the state-law opt-out Rule 23 action.The Third Circuit stayed the trial. Citizens had a sufficient likelihood of success on its mandamus petition, and mandamus is the only relief available. By compelling the FLSA opt-in collective action trial before deciding Rule 23 class certification, the district court “created a predicament for others to unravel” and “clearly and indisputably erred.” Allowing the planned FLSA collective action trial would publicly preview the evidence common to the FLSA and state-law claims, giving potential Rule 23 class members an enormous informational advantage in any subsequent “do-over.” Citizens would suffer irreparable injury absent a stay; a stay will not substantially injure the plaintiffs. View "In re: Citizens Bank, N.A." on Justia Law

Three drivers for the rideshare company, Lyft, each filed separate representative actions against Lyft under the Private Attorneys General Act of 2004 (PAGA) (Lab. Code 2698), alleging that Lyft misclassified its California drivers as independent contractors rather than employees, thereby violating multiple provisions of the Labor Code. Following mediation in 2019, one driver, Turrieta, and Lyft reached a settlement. After Turrieta moved for court approval of the settlement, the other drivers sought to intervene and object to the settlement, arguing that Lyft had engaged in a “reverse auction” by settling with Turrieta for an unreasonably low amount and that the settlement contained other provisions that were unlawful and inconsistent with PAGA’s purpose. The trial court found that they lacked standing and approved the settlement.The court of appeal affirmed. The status of the other drivers as PAGA plaintiffs in separate actions does not confer standing to move to vacate the judgment or challenge the judgment on appeal. While they may appeal from the court’s implicit order denying them intervention, there was no error in that denial. View "Turrieta v. Lyft, Inc." on Justia Law

Plaintiff Irean Amaro filed this wage and hour class action and Private Attorneys General Act (PAGA) lawsuit against defendant Anaheim Arena Management (AAM) in 2017. At the time, there were already two existing class actions asserting the same claims: one in 2014, and the other in 2016. About a month after filing her lawsuit, Amaro and AAM reached a global settlement that covered the claims asserted in the two prior class actions. The plaintiffs from the prior actions, which included intervener Rhiannon Aller, were not involved in those settlement discussions. Aller intervened in this lawsuit and objected to the settlement. Initially, the trial court denied preliminary approval of the settlement on grounds Amaro had not given the court enough information to determine the adequacy of the settlement. Amaro then engaged in extensive informal discovery and entered into an amended settlement with AAM. The court approved the amended settlement over Aller’s objections and entered judgment per the settlement’s terms. Aller appealed, claiming the court’s approval of the settlement was erroneous for two reasons: (1) the class members’ release in the settlement was improper because it extended to claims outside the scope of Amaro’s complaint, waived class members’ (from all class actions) claims under the Fair Labor Standards Act (FLSA) without obtaining their written consent, and released PAGA claims beyond the limitations period of Amaro’s own PAGA claim; and (2) the court abused its discretion in finding the settlement was not the product of a collusive reverse auction. The Court of Appeal agreed the release was overbroad, but there was nothing inherently wrong with AAM's bypassing the other class action plaintiffs and undercutting their claims by negotiating a settlement with Amaro that extinguished the other suits. Though the Court rejected most of Aller’s arguments, it reversed the judgment and remanded with directions due to the overbreadth of the release. View "Amaro v. Anaheim Arena Management" on Justia Law