Justia Class Action Opinion Summaries

Plaintiff alleged that, after her employment terminated, defendants failed to pay all of her final wages. She filed a putative class action under Labor Code sections 201-203, also asserting a representative Private Attorneys General Act (PAGA) claim seeking civil penalties on behalf of plaintiff and other aggrieved employees. Defendants submitted an arbitration agreement signed by plaintiff, stating any disputes would be submitted to arbitration and that “[a]ny such claims must be submitted on an individual basis only and I hereby waive the right to bring or join any type of collective or class claim in arbitration, in any court, or in any other forum.” Defendants conceded that the agreement cannot waive the representative PAGA claim. The trial court compelled arbitration of plaintiff’s individual claim, dismissed the class claims, bifurcated the representative PAGA claim, and stayed the PAGA claim pending the completion of arbitration. The court of appeal concluded the order is nonappealable; the order does not appear to constitute a de facto final judgment for absent plaintiffs. The putative class members/aggrieved employees under PAGA because their PAGA claims remain pending. View "Young v. REMX" on Justia Law

Steve Maddox and eight other named relators (collectively, Maddox) brought this original action in mandamus against the village of Lincoln Heights and several of the village’s officials (collectively, the village). Maddox alleged that several classes of people who work for or have worked for the village had not been provided employee benefits owed to them and requested a writ directing the village to provide the withheld benefits. The parties filed a joint motion for preliminary approval of a class action settlement consisting of money payments to class members. The Supreme Court referred the case to mediation, with instructions for the parties to attempt an out-of-court settlement without court approval, holding that the Court lacked jurisdiction to preside over this monetary settlement because no class had yet been certified and nothing prevented the parties from settling the case without the approval of the Court. View "State ex rel. Maddox v. Village of Lincoln Heights" on Justia Law

This appeal addressed a collective action alleging nonpayment of overtime, as required by state law under Labor Code section 510 and federal law under the Fair Labor Standards Act of 1938 (FLSA). Plaintiff Jose Luis Morales and 177 other similarly situated plaintiffs (collectively, appellants) sued their employer, the 22nd District Agricultural Association of the State of California (the DAA), alleging nonpayment of overtime. Appellants were seasonal employees of the DAA who assist with amusement and seasonal operations. Appellants contended that reversal of the judgment in favor of the DAA on their FLSA claim was required because the trial court: (1) improperly denied their nonsuit motion; (2) erred in instructing the jury; (3) provided an erroneous special verdict form; and (4) improperly excluded party witnesses from the courtroom. The Court of Appeal found that appellants did not meet their burden to demonstrate reversible error. Furthermore, the Court concluded that the trial court properly sustained the DAA's demurrer to appellants' section 510 claim, but erred in denying leave to amend. View "Morales v. 22nd Dist. Agricultural Assn." on Justia Law

Plaintiffs, a class of former employees of Continental, filed suit against Celadon, alleging that Celadon violated the Worker Adjustment and Retraining Notification (WARN) Act, 29 U.S.C. 2102. The district court certified the class, granted partial summary judgment to the employees, and awarded damages. Viewing the Celadon–Continental transaction in light of a common-sense approach, the court agreed with the district court that the transaction was more than merely a sale of assets. Consequently, responsibility to provide notice passed from Continental to Celadon under the WARN Act where plaintiffs became employees of Celadon. The court also concluded that the district court did not abuse its discretion in requiring Celadon to bear the burden of establishing that certain members of the certified class should be excluded; the district court did not abuse its discretion in denying Celadon's motion to decertify the class; and the district court did not err in not adopting the magistrate judge's report and recommendation regarding class membership. In regard to the issue of damages, the court concluded that the district court did not abuse its discretion by shifting the burden to Celadon after the employees made their initial showing. After thoroughly reviewing the evidentiary rulings of the district court in light of the burden-shifting framework it employed, the court held that the district court did not commit a clear and prejudicial abuse of discretion. Finally, the district court did not abuse its discretion in refusing to reduce Celadon's liability. Accordingly, the court affirmed the judgment. View "Day v. Celadon Trucking Servs." on Justia Law

The "Olson I" opinion examined the extent to which the 1976 amendment to the then-existing Government Code section 68203 aimed at placing a limit on cost of living adjustments (COLA's) for the salaries payable to active jurists and (derivatively) also limiting the pensions payable to certain judicial pensioners, could constitutionally be applied to those active jurists and judicial pensioners. Since Olson I, numerous courts have addressed issues stemming from Olson I, including whether a constitutional amendment designed to supersede Olson I and deprive active jurists and certain judicial pensioners of the benefits provided by the uncapped COLA's was constitutional, and whether interest was due on the payments owed to active and retired judges under the judgment announced in Olson I. This case represented the latest progeny of Olson I. Petitioner Faye Staniforth (and others similarly situated) alleged, as its principal claim against respondent The Judges' Retirement System (JRS), that JRS had not adhered to its obligations to pensioners under their interpretation of Olson I and that, as a result, over three decades worth of pension payments had been underpaid to pensioners. The Olson I claims raised by pensioners sought to compel the JRS to adhere to pensioners' interpretation of Olson I and to recalculate the amount of judicial pensions owed to pensioners using the uncapped COLA's, and to pay arrearages and interest for the decades of underpaid pension payments. The Court of Appeal concluded, contrary to pensioners' Olson I claims, pensioners were not entitled under Olson I to perpetual uncapped COLA increases to their pensions. JRS demurred to an amended petition, arguing that all the stated claims, which sought recovery for payments to the retired jurists that allegedly should have been paid over two decades before the present action was filed, were barred by the statute of limitations under any possibly applicable statute. Petitioners appealed, but finding no error in the trial court's sustaining JRS' demurrer without leave to amend, and dismissal of the action, the Court of Appeal affirmed. View "Staniforth v. The Judges' Retirement System" on Justia Law

After EyeCare Specialties, P.C. of Lincoln terminated the employment of Cindy Marshall, Marshall sued, alleging that EyeCare discriminated against her because of her skin condition, tremors, and perceived disability related to her past prescription drug abuse. The district court granted summary judgment in favor of EyeCare. The Supreme Court reversed, holding (1) a genuine issue of material fact existed concerning whether EyeCare discriminated against Marshall because of her skin condition and tremors, both of which EyeCare perceived to substantially limit Marshall’s ability to work; and (2) Marshall failed to present evidence that EyeCare discriminated against her for having a perceived drug addiction that substantially limited one or more major life activities. View "Marshall v. EyeCare Specialties, P.C." on Justia Law

Tyson employees working in the kill, cut, and retrim departments of an Iowa pork processing plant are required them to wear protective gear. The exact composition of the gear depends on the tasks a worker performs on a given day. Tyson compensated some, but not all, employees for donning and doffing, and did not record the time each employee spent on those activities. Employees sued under the Fair Labor Standards Act (FLSA) and an Iowa wage law. They sought certification of their state claims as a class action under FRCP 23 and of their FLSA claims as a “collective action,” 29 U.S.C. 216. The court concluded that common questions, such as whether donning and doffing were compensable, were susceptible to classwide resolution even if not all of the workers wore the same gear. To show that they each worked more than 40 hours a week, inclusive of time spent donning and doffing, the employees primarily relied on a study performed by an industrial relations expert, Dr. Mericle. He conducted videotaped observations analyzing how long various donning and doffing activities took, averaged the time, and produced an estimate of 18 minutes a day for the cut and retrim departments and 21.25 minutes for the kill department. These estimates were added to the timesheets of each employee. The jury awarded about $2.9 million. The Eighth Circuit and Supreme Court affirmed. The most significant question common to the class is whether donning and doffing is compensable under FLSA. Because a representative sample may be the only feasible way to establish liability, it cannot be deemed improper merely because the claim was brought on behalf of a class. Each class member could have relied on the Mericle sample to establish liability had each brought an individual action. View "Tyson Foods, Inc. v. Bouaphakeo" on Justia Law

Farmworkers filed a class action lawsuit against four corporate defendants. Two questions of Washington law were certified to the Washington Supreme Court, arising from this suit: The first question implicated RCW 19.30.010(2)'s definition of a "farm labor contractor." The second question implicated RCW 19.30.200, which imposed joint and several liability for Farm Labor Contractor Act (FLCA) violations. The certified questions required the Supreme Court to decide whether defendant-appellant NW Management and Realty Services Inc. was a "farm labor contractor" under RCW 19.30.01 0(2) and, if so, whether the other defendants "knowingly use[ d]" its services under RCW 19.30.200 (There is no dispute that NW was unlicensed at all times relevant to this case). The plain language of the FLCA compels the Washington Court to answer yes to both certified questions. View "Saucedo v. John Hancock Life & Health Ins. Co." on Justia Law

Plaintiffs filed a class-action suit against their former employer, Huntington Bank, alleging that the Bank failed to pay overtime compensation as required by the Fair Labor Standards Act, 29 U.S.C. 201-219. Plaintiffs moved to conditionally certify a class of all current and former employees whose primary job duty consisted of “underwriting,” or “providing [Huntington’s] credit products to customers after reviewing and evaluating the loan applications against [the Bank’s] credit standards and guidelines that governed when to provide those credit products to those customers.” The court certified a smaller class of underwriters. The court found, and the Sixth Circuit affirmed, that those who worked with residential-loan products are administrative employees and not entitled to overtime pay. Their job duties related to the general business operations of the Bank, and they exercised discretion and independent judgment when performing those duties. View "Lutz v. Huntington Bancshares, Inc." on Justia Law

Plaintiffs brought suit under the Fair Labor Standards Act (FLSA) against their employer, FTS, a cable-television business for which the plaintiffs work or worked as cable technicians. The district court certified the case as an FLSA collective action, allowing 293 other technicians to opt in. FTS Technicians are paid pursuant to a piece-rate compensation plan; each assigned job is worth a set amount of pay, regardless of the amount of time it takes to complete the job. FTS Technicians are paid by applying a .5 multiplier to their regular rate for overtime hours. They allege that FTS implemented a company-wide time-shaving policy that required its employees to systematically underreport their overtime hours. Technicians either began working before their recorded start times, recorded lunch breaks they did not take, or continued working after their recorded end time. Technicians also presented documentary evidence and testimony showing that FTS’s time-shaving policy originated with FTS’s corporate office. A jury returned verdicts in favor of the class, which the district court upheld before calculating and awarding damages. The Sixth Circuit affirmed certification of the case as a collective action and a finding that sufficient evidence supports the verdicts, but reversed the calculation of damages. View "Monroe v. FTS USA, LLC" on Justia Law