Justia Class Action Opinion Summaries

A former employee, Campbell, filed a putative class action lawsuit against her employer, Sunshine Behavioral Health, LLC, alleging wage and hour violations. Campbell claimed that employees were not paid proper overtime, were required to work through meal and rest breaks without compensation, were not paid minimum wage, and were not paid in a timely manner. Sunshine initially proceeded with litigation and agreed to participate in mediation. However, Sunshine later claimed to have discovered an arbitration agreement signed by Campbell, which included a class action waiver.The Superior Court of Orange County found that Sunshine had waived its right to compel arbitration. Despite allegedly discovering the arbitration agreement in November 2022, Sunshine continued to engage in mediation discussions and did not inform Campbell or the court of its intent to compel arbitration until March 2023. Sunshine's delay and conduct were deemed inconsistent with an intent to arbitrate, leading the court to conclude that Sunshine had waived its right to arbitration.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case and affirmed the lower court's decision. The appellate court found clear and convincing evidence that Sunshine had waived its right to arbitration. The court noted that Sunshine's actions, including agreeing to mediation on a class-wide basis and delaying the motion to compel arbitration, were inconsistent with an intent to arbitrate. The court emphasized that Sunshine's conduct demonstrated an intentional abandonment of the right to arbitrate, thus affirming the order denying the motion to compel arbitration. View "Campbell v. Sunshine Behavioral Health" on Justia Law

Plaintiffs Marla Knudsen and William Dutra, representing a class of similarly situated individuals, filed a class action lawsuit under the Employee Retirement Income Security Act (ERISA) against MetLife Group, Inc. They alleged that MetLife, as the administrator and fiduciary of the MetLife Options & Choices Plan, misappropriated $65 million in drug rebates from 2016 to 2021. Plaintiffs claimed this misappropriation led to higher out-of-pocket costs for Plan participants, including increased insurance premiums.The United States District Court for the District of New Jersey dismissed the case for lack of standing. The court concluded that the plaintiffs did not demonstrate a concrete and individualized injury. It reasoned that the plaintiffs had no legal right to the general pool of Plan assets and had not shown that they did not receive their promised benefits. The court found the plaintiffs' claims that they paid excessive out-of-pocket costs to be speculative and lacking factual support.The United States Court of Appeals for the Third Circuit affirmed the District Court's dismissal. The Third Circuit held that the plaintiffs failed to establish an injury-in-fact, as their allegations of increased out-of-pocket costs were speculative and not supported by concrete facts. The court noted that the plaintiffs did not provide specific allegations showing how the misappropriated drug rebates directly caused their increased costs. The court emphasized that financial harm must be actual or imminent, not conjectural or hypothetical, to satisfy Article III standing requirements. Consequently, the plaintiffs lacked standing to pursue their ERISA claims. View "Knudsen v. MetLife Group Inc" on Justia Law

Dan Hamilton, an employee at an Amazon warehouse in Aurora, Colorado, received both holiday pay and holiday incentive pay. Holiday pay was his regular hourly rate for company holidays, regardless of whether he worked. Holiday incentive pay was one and one-half times his regular rate for hours worked on holidays. Hamilton filed a class action complaint alleging Amazon violated the Colorado Wage Act by not including holiday incentive pay in the calculation of his overtime pay.The case was initially filed in Arapahoe County District Court but was removed to the United States District Court for the District of Colorado. Amazon moved to dismiss the complaint, arguing that holiday incentive pay could be excluded from the regular rate of pay under both Colorado law and the Federal Fair Labor Standards Act (FLSA). The federal district court agreed with Amazon, ruling that Colorado law did not require the inclusion of holiday incentive pay in the regular rate of pay calculation, and dismissed Hamilton's complaint. Hamilton appealed to the Tenth Circuit, which then certified a question of law to the Supreme Court of Colorado.The Supreme Court of Colorado reviewed the certified question and concluded that holiday incentive pay must be included in the calculation of the regular rate of pay under Colorado law. The court found that the plain language of the relevant regulations, specifically 7 Colo. Code Regs. § 1103-1:1.8 and 1.8.1, mandated the inclusion of all compensation for hours worked, including holiday incentive pay. The court rejected Amazon's arguments that holiday incentive pay could be excluded and that Colorado law should be interpreted in line with the FLSA. The court held that holiday incentive pay is a form of shift differential and must be included in the regular rate of pay calculation. View "Hamilton v. Amazon.com Services" on Justia Law

A group of Union Pacific Railroad Company employees filed a class action lawsuit against the company, alleging that its fitness-for-duty program violated the Americans with Disabilities Act (ADA). Todd DeGeer, believing he was part of this class, filed an Equal Employment Opportunity Commission (EEOC) charge and an individual lawsuit after the class was decertified. DeGeer argued that his claims were tolled under the American Pipe & Construction Co. v. Utah doctrine. The district court dismissed his claims as untimely, finding that DeGeer was not a member of the narrowly defined class.The United States District Court for the District of Nebraska initially certified a class that included Union Pacific employees subjected to fitness-for-duty evaluations due to a reportable health event. DeGeer was on a list of employees provided by Union Pacific and submitted a declaration supporting the plaintiffs' certification motion. However, the class definition was later narrowed, and the district court certified the class under this new definition. The Eighth Circuit Court of Appeals later reversed the class certification, leading DeGeer to file his individual claims.The United States Court of Appeals for the Eighth Circuit reviewed the case and reversed the district court's decision. The Eighth Circuit held that DeGeer was entitled to American Pipe tolling because the revised class definition did not unambiguously exclude him. The court emphasized that ambiguities in class definitions should be resolved in favor of applying tolling. Consequently, DeGeer's claims were tolled during the pendency of the class action, making his individual lawsuit timely. The case was remanded for further proceedings. View "DeGeer v. Union Pacific Railroad Co." on Justia Law

Four former Tesla employees, Sharonda Taylor, Shaka Green, Tatianna Smith, and Zenobia Milligan, requested personnel records from Tesla under the California Labor Code. These individuals are also part of a class action lawsuit, Vaughn v. Tesla, which alleges racial discrimination and harassment at Tesla's Fremont plant. Despite the requests, Tesla did not provide the requested records, citing a stay in the Vaughn case due to an ongoing appeal. The plaintiffs then filed a Private Attorneys General Act (PAGA) action against Tesla for failing to comply with the Labor Code.The Superior Court of California, County of Alameda, denied Tesla's anti-SLAPP motion, which argued that the PAGA claims arose from protected petitioning activity related to the Vaughn case. The court found that the plaintiffs' requests for personnel records were independent of the Vaughn litigation and were merely an exercise of their statutory rights under the Labor Code.The California Court of Appeal, First Appellate District, Division Four, affirmed the lower court's decision. The appellate court held that Tesla's refusal to provide the requested records did not constitute protected activity under the anti-SLAPP statute. The court distinguished this case from Crossroads Investors, L.P. v. Federal National Mortgage Assn., noting that the plaintiffs' PAGA claims did not rely on any "written or oral statement or writing" by Tesla. The court also found that Tesla's conduct did not meet the criteria for protection under the anti-SLAPP statute's "catchall" provision, as it did not contribute to any public issue or debate. Consequently, the court affirmed the denial of Tesla's anti-SLAPP motion. View "Taylor v. Tesla, Inc." on Justia Law

Robert Anthony Zaragoza, a former brakeman and train conductor for Union Pacific Railroad Company, was terminated in 2015 after testing positive for cocaine but was later reinstated. In 2016, he failed a color vision test and subsequent retests, leading to his removal from service and denial of recertification as a conductor. Zaragoza contested these results, submitting medical reports attesting to his adequate color vision, but was not reinstated.Zaragoza argued that his claims were tolled from 2016 to 2020 due to his inclusion in a class action against Union Pacific, Harris v. Union Pacific Railroad Co. The district court for the Western District of Texas dismissed his claims as untimely, finding that the tolling ended with the class certification order in February 2019, and the statute of limitations expired before Zaragoza filed his EEOC charge in March 2020.The United States Court of Appeals for the Fifth Circuit reviewed the case and determined that Zaragoza was included in both the putative and certified class definitions in the Harris class action. The court held that the statute of limitations for Zaragoza's claims was tolled during the pendency of the Harris class action, from the time his claims accrued until the Eighth Circuit decertified the class in March 2020. Consequently, Zaragoza's claims were timely when he filed his EEOC charge.The Fifth Circuit reversed the district court's dismissal of Zaragoza's disability discrimination claims and remanded the case for further proceedings, declining to address Union Pacific's alternate grounds for summary judgment. View "Zaragoza v. Union Pacific Railroad" on Justia Law

Four former Tesla employees, Sharonda Taylor, Shaka Green, Tatianna Smith, and Zenobia Milligan, requested personnel records from Tesla through their counsel, Bryan Schwarz Law (BSL), under the California Labor Code. These individuals are also part of a class action lawsuit, Vaughn v. Tesla, which alleges racial discrimination and harassment at Tesla's Fremont factory. During the Vaughn litigation, BSL sent Tesla privacy waivers and statutory personnel records requests on behalf of numerous employees, including the plaintiffs. Tesla did not respond to these requests, citing a stay in the Vaughn proceedings due to an appeal.The Superior Court of California, County of Alameda, denied Tesla's anti-SLAPP motion, which sought to strike the plaintiffs' PAGA complaint. The court found that Tesla failed to show that the plaintiffs' claims arose from protected petitioning activity under the anti-SLAPP statute. The court ruled that the plaintiffs were exercising their statutory rights to inspect and copy personnel records, independent of the Vaughn litigation.The California Court of Appeal, First Appellate District, Division Four, affirmed the lower court's decision. The appellate court held that Tesla's refusal to provide the requested personnel records did not constitute protected petitioning activity under the anti-SLAPP statute. The court distinguished this case from Crossroads Investors, L.P. v. Federal National Mortgage Assn., noting that the plaintiffs' claims did not involve any "written or oral statement or writing" by Tesla. The court also found that Tesla's conduct did not further any public issue or contribute to public debate, as required under the anti-SLAPP statute's catchall provision. Consequently, the appellate court affirmed the denial of Tesla's anti-SLAPP motion. View "Taylor v. Tesla, Inc." on Justia Law

A trial court found that Yakima HMA LLC wrongfully withheld nearly $1.5 million in wages from its nurses over five years. In 2015, the Washington State Nurses Association (WSNA) filed a claim on behalf of 28 nurses, including Daniel Campeau. The trial court ruled in favor of WSNA, but years later, the Supreme Court of Washington reversed this decision, stating that WSNA lacked associational standing. Before the mandate was issued, Campeau filed a class action suit to recover the unpaid wages.The trial court agreed with Campeau, allowing the case to proceed under the doctrine of equitable tolling, reasoning that Campeau had diligently pursued his claims through the WSNA action and reasonably relied on the union to protect his rights. Yakima HMA appealed, and the Court of Appeals reversed the trial court's decision, concluding that American Pipe tolling was not applicable in Washington and that equitable tolling was not warranted without evidence of bad faith or misconduct by Yakima HMA.The Supreme Court of Washington reviewed the case de novo. The court held that equitable tolling could be appropriate even without bad faith by the defendant when associational standing fails, and a member promptly files a follow-on class action. The court found that equitable tolling was consistent with the purposes of the underlying labor laws and statutes of limitations, and it would prevent an unjust windfall to Yakima HMA. Therefore, the court reversed the Court of Appeals and remanded the case to the trial court for further proceedings. View "Campeau v. Yakima HMA, LLC" on Justia Law

This case is a class action involving commercial truck drivers who claimed they were not paid properly by Werner Enterprises, Inc., and Drivers Management, LLC. The drivers alleged that they were not adequately compensated for off-duty time spent on short rest breaks and time spent resting in their trucks’ sleeper-berths. The case has been appealed multiple times, with the court previously vacating a jury verdict in favor of the drivers because the district court improperly allowed the drivers to submit an expert report after the deadline. On remand, the district court entered judgment in favor of the defendants. The drivers appealed again, and the court vacated the judgment and remanded the case back to the district court to conduct an analysis regarding whether the expert report should be excluded as a discovery sanction and whether the district court should appoint an independent expert.On remand, the district court concluded that exclusion of the drivers’ expert report was the appropriate sanction for its late disclosure and that appointment of an independent expert was not appropriate. It then entered judgment in favor of the defendants. The drivers appealed this decision, asserting that the district court erred in its analysis. The defendants cross-appealed, asserting that the drivers’ notice of appeal was untimely, requiring dismissal of the appeal.The United States Court of Appeals for the Eighth Circuit rejected the defendants’ contention on cross-appeal and affirmed the judgment of the district court. The court found that the district court did not abuse its discretion in excluding the expert report and denying the drivers’ motion for a new trial. The court also found that the district court did not err in declining to appoint an expert and in entering judgment in favor of the defendants. View "Petrone v. Werner Enterprises, Inc." on Justia Law

The plaintiff, Mary Rodgers-Rouzier, worked as a bartender on steamboats operated by American Queen. She alleged that she and her coworkers were wrongly denied overtime wages. Rodgers-Rouzier filed a suit as a collective action, and over one hundred of her coworkers joined her proposed collective action. Meanwhile, American Queen moved to dismiss the case, arguing that Rodgers-Rouzier had agreed to arbitration. The district court denied the motion, but American Queen moved again to dismiss based on the arbitration agreement, this time invoking Indiana state law. The district court granted this motion, over Rodgers-Rouzier’s objections.The district court had previously denied American Queen's motion to dismiss the case for improper venue because Rodgers-Rouzier had agreed to arbitration. However, American Queen then moved again to dismiss based on the arbitration agreement, this time invoking Indiana state law. The district court granted this motion, over Rodgers-Rouzier’s objections that American Queen had waived its argument and the court lacked authority to apply Indiana law in this context. The court further determined that all the workers who had filed consent forms were not parties to the action.The United States Court of Appeals for the Seventh Circuit reversed the district court's decision. The court concluded that although American Queen’s arguments were not waived and the court had authority to enforce the arbitration agreement under Indiana law, Indiana law would hold American Queen to its bargain that its arbitration agreement was governed by the Federal Arbitration Act (FAA). Therefore, Rodgers-Rouzier’s case may continue in federal court. The court did not decide whether it may do so as a collective action and left that question for further litigation. View "Rodgers-Rouzier v. American Queen Steamboat Operating Company, LLC" on Justia Law