Justia Class Action Opinion Summaries

Petitioners, who were all employed by Respondent as public school bus drivers or dispatchers, claimed that Respondent failed to compensate them for regular and overtime wages in weeks in which they worked more than forty hours. Petitioners filed a class-action complaint in federal district court, alleging violations of the federal Fair Labor Standards Act and the Arkansas Minimum Wage Act (AMWA). Respondents opposed Petitioners' motion to amend their complaint, contending the amendment would be futile because Petitioners' AMWA claims were barred by the three-year statute of limitations set forth in Ark. Code Ann. 16-56-105. The Supreme Court accepted certification to answer what the appropriate statute of limitations was for a private cause of action pursuant to Ark. Code Ann. 11-4-218(e), which allows an employee to bring a private cause of action for relief against an employer for minimum wages, including overtime wages, but does not include a specific limitations provision. After acknowledging the Court's long history of applying section 16-56-105's three-year limitation period for statutorily created liabilities that do not contain an express limitations period, the Court answered that a three-year statute of limitations would apply to private causes of action brought pursuant to AMWA. View "Douglas v. First Student, Inc." on Justia Law

Plaintiffs, current or former "franchisee" shuttle van drivers for SuperShuttle in various parts of California, filed a putative class action alleging that plaintiffs were misclassified as "independent contractors" when, in truth, they were "employees" under California law. Plaintiffs alleged that they had consequently been deprived of the full protections provided to employees under the California Labor Code, including overtime and minimum wages, reimbursement of business expenses and deductions wrongfully taken from wages, and meal period pay. The district court granted SuperShuttle's motion to dismiss plaintiffs' state law claims holding that it lacked subject matter jurisdiction. The court held that the third prong in San Diego Gas & Electric Co. v. Superior Court (Covalt) was not satisfied, the California Public Utilities Code 1759 was not implicated, and the district court retained subject matter jurisdiction over the case. On remand, the district court could determine whether the SuperShuttle drivers were employees or independent contractors under California law without hindering or interfering with PUC decisions or policies. View "Kairy, et al. v. Supershuttle Int'l, et al." on Justia Law

This appeal and cross-appeal concerned the pension benefits owed to plaintiff, a retired carpenter, and members of a class he purported to represent. Plaintiff asserted that the pension fund was guilty of seven violations of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., and sought declaratory and injunctive relief. The court agreed with the district court that defendants' interpretations of certain plan language was arbitrary and capricious and therefore affirmed the district court's award of summary judgment to plaintiff on his individual claims for miscalculation of pension benefits. The court concluded, however, contrary to the district court, that the six-year statute of limitations applicable to plaintiff's and each other putative class member's ERISA claims began to run when each pensioner knew or should have known that defendants had miscalculated the amount of his pension benefits, and that he was being underpaid as a result. Therefore, the court vacated the district court's judgments certifying the plaintiff class, granting summary judgment to the class, and granting prejudgment interest to the class members. The court remanded for further factfinding with regard to when each putative class member became, or should have become, aware of his alleged injury so as to begin the running of the statute of limitations as applied to him.

Plaintiffs, on behalf of themselves and all other similarly situated, filed a complaint alleging that defendants violated the minimum wage and overtime provisions of the Fair Labor Standards Act (FLSA), 29 U.S.C. 201-19, by requiring waiters to share tips with tip-ineligible employees. Plaintiffs also alleged that Park Avenue also violated various provisions of the New York Labor Law by requiring servers to share tips with tip-ineligible employees and by failing to pay waiters for an extra hour's work when their workdays lasted more than ten hours. Defendants appealed from the district court's order granting plaintiffs' motion for class certification. The court held that plaintiffs provided ample and sufficient evidence as to the elements of Rule 23(a)(1)-(4) and Rule 23(b)(3) for it to uphold the district court's findings and conclusions with respect to each of the Rule 23 requirements. Accordingly, the court affirmed the district court's order.

Plaintiffs, six current and former African-American employees, brought suit against Nucor alleging racial discrimination in violation of 42 U.S.C. 1981 and Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-2000e-17. The district court denied plaintiffs' requests for class certification, granted summary judgment in favor of Nucor on several claims and the case proceeded to trial. A jury returned verdicts against Nucor and awarded each plaintiff monetary damages. The parties appealed and cross-appealed, contesting various rulings by the district court. The court held that the district court did not abuse its discretion in believing that evidence of a previous enforcement action alleging race discrimination at the Blytheville plant was relevant to the credibility of plaintiffs' allegations. The court also held that the district court properly admitted certain statements at issue. The court further held that because Nucor failed to renew its motion under Rule 50(b), the court was without power to disturb the district court's entry of judgment on the jury's punitive damages award. The court finally held that the district court did not abuse its discretion by concluding that plaintiffs had not met their burden of demonstrating the commonality of their claims and that summary judgment was warranted on plaintiffs' disparate impact claims, failure-to-train disparate treatment claims, and failure-to-promote disparate treatment claims. Accordingly, the judgment of the district court was affirmed.

Costco appealed the district court's order granting class certification in a class action brought by Shirley Ellis, Leah Horstman, and Elaine Sasaki (plaintiffs), alleging that Costco's promotional practices discriminated based on gender. The court held that at least one plaintiff (Sasaki) had standing to bring suit. The court also held that the district court abused its discretion by applying the wrong legal standard in its analyses of commonality and typicality under Rule 23(a). Accordingly, the court vacated the district court's findings on those issues and remanded for application of the correct standard. The court further held that, although the district court correctly determined that Sasaki was an adequate class representative, the court held that Ellis and Horstman were inadequate representatives for pursuing injunctive relief, given that they were former employees, and remanded for the district court to consider whether they were adequate representatives if a (b)(3) class was certified. Therefore, the court vacated the district court's certification of a class pursuant to Rule 23(b)(2) and remanded for reconsideration.

Appellants, current and former shuttle bus drivers at the Minneapolis-St.Paul International Airport, brought suit against appellees in Minnesota state court alleging misclassifications of its drivers as franchisees rather than employees. At issue was whether the district court erred in granting the motion to compel arbitration, erred in enforcing the class action waiver clauses in the drivers' contracts, and erred in dismissing the federal action instead of staying it pending arbitration. The court held that the district court did not err in granting the motion to compel arbitration where appellants agreed to have an arbitrator determine threshold questions of arbitrability and therefore, appellants agreed to have the arbitrator decide whether the Federal Arbitration Act's (FAA), 9 U.S.C. 1, transportation worker exemption applied. The court also held that AT&T Mobility LLC v. Concepcion foreclosed appellants' claim that the district court erred in concluding the class action waivers were enforceable where the Supreme Court recently held that the FAA preempted a state-law-based challenge to the enforceability of class action waivers. The court held that, under the circumstances, the district court abused its discretion in dismissing the action rather than staying it pending completion of the arbitration.

When an employee left the company in 1997, took a $47,850 lump sum distribution of his pension. He later believed that the payment should have included the present value of future cost of living adjustments that would have been included had he received his pension as an annuity. In 2002, he filed a class action suit. The district court granted summary judgment on liability in favor of the class and the Seventh Circuit affirmed, holding that a COLA is an accrued benefit, as defined in ERISA, 29 U.S.C. 1002(23)(A). Before the district court ruled, the parties reached a settlement that each early retiree would receive roughly 3.5% of her original lump sum, unless the COLA on a normal-retirement-age-based annuity outweighed her early-retirement subsidy, a rare situation. The district court approved the proposed settlement and awarded attorney's fees. Objectors were not allowed to opt out. The Seventh Circuit affirmed, upholding determinations that the settlement was reasonable; that class counsel had adequately represented the early retirees and that further subclasses were unnecessary; that opt-out should be denied; and concerning attorney fees.

A registered nurse initiated a collective action on behalf of herself and all similarly situated individuals, alleging defendants violated the Fair Labor Standards Act, 29 U.S.C. 207 and 216(b), when they implemented a policy subjecting the pay of certain employees to an automatic meal break deduction whether or not they performed compensable work during breaks. Defendants made an offer of judgment under Fed. R. Civ. P. 68 in the amount of "$7,500.00 in alleged unpaid wages, plus attorneys' fees, costs and expenses as determined by the Court." The district court dismissed for lack of subject matter jurisdiction. The Third Circuit reversed, first noting that the FLSA does not contain conditional class certification language. The court nonetheless applied the "relation back doctrine," which allows a district court to retain jurisdiction over a matter that would appear moot after expiration of a named plaintiff's individual claims, to prevent use of a Rule 68 offer as a "sword."

Petitioners Wayne Tomlinson, Alice Ballesteros and Gary Muckelroy appealed the dismissal of their claims against El Paso Corporation and the El Paso Pension Plan (collectively "El Paso") brought under the Age Discrimination in Employment Act (ADEA) and the Employee Retirement Income Security Act (ERISA). Plaintiffs' claims concern "wear-away" periods that occurred during El Paso's transition to a new pension plan. They contended that the wear-away periods violated the ADEA's prohibition on age discrimination and the anti-backloading and notice provisions of ERISA. The trial court found that El Paso's transition favored, rather than discriminated against, older employees; and the plan was frontloaded rather than backloaded. Accordingly, the Tenth Circuit's review concluded that ERISA did not require notification of wear-away periods so long as employees were informed and forewarned of plan changes. The Court affirmed the lower court's decision dismissing Petitioners' claims.