Justia Class Action Opinion Summaries

Plaintiffs filed a putative class action against a hospital network and senior executives, claiming to represent more than 12,000 employees deprived of compensation for work performed during their meal break, for work performed before and after shifts, and for time spent attending training sessions, based on the Massachusetts Payment of Wages Act, Mass. Gen. Laws ch. 149, 148; the Massachusetts Minimum Fair Wages Act, Mass. Gen. Laws ch. 151, 1A and 15--or breach of contract or implied contract; money had and received; quantum meruit/unjust enrichment; fraud; negligent misrepresentation; conversion; equitable and promissory estoppel. Defendants claimed that the Labor Management Relations Act, 29 U.S.C. 185, precluded state law claims. The district court dismissed. The First Circuit vacated and remanded, stating that the district court. It is not clear that either named plaintiff is covered by a collective bargaining agreement.

The issues central to this case are whether donning doffing poultry processing workers’ personal protective equipment is "changing clothes" under 29 U.S.C. 204 and whether a turkey processing plant is a “food and beverage industry” under Colorado law. Plaintiffs/Appellants Clara Salazar and Juanita Ybarra brought suit on behalf of hourly production employees at Defendant/Appellee Butterball, LLC’s Colorado turkey processing plant. Plaintiffs claimed that Butterball’s failure to compensate them for the time spent changing in and out of their personal protective equipment violated the Fair Labor Standards Act (FLSA) and the Colorado Minimum Wage Order. The district court entered summary judgment in Butterball’s favor, holding that the donning and doffing time was excluded and that the Colorado Wage Order did not apply to Butterball. Upon consideration of the submitted briefs and the applicable legal authority, the Tenth Circuit affirmed the district court’s decisions. The Court found that donning and doffing time is not "hours worked" as defined by FLSA. Furthermore, Butterball is a reseller, and the Colorado regulation applied only to employers "that sell food directly to the consuming public." Accordingly, the Court affirmed the district court’s decisions.

Respondents, current or former employees of petitioner Wal-Mart, sought judgment against the company for injunctive and declaratory relief, punitive damages, and backpay, on behalf of themselves and a nationwide class of some 1.5 million female employees because of Wal-Mart's alleged discrimination against women in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-1 et seq. At issue was whether the certification of the plaintiff class was consistent with Federal Rules of Civil Procedure 23(a) and (b)(2). The Court held that certification of the plaintiff class was not consistent with Rule 23(a) where proof of commonality necessarily overlapped with respondents' merits contention that Wal-mart engaged in a pattern or practice of discrimination and without some glue holding together the alleged reasons for the employment decisions, it would be impossible to say that examination of all the class members' claims would produce a common answer to the crucial discrimination question. The Court concluded that in a company Wal-Mart's size and geographical scope, it was unlikely that all managers would exercise their discretion in a common way without some common direction and respondents' attempt to show such direction by means of statistical and anecdotal evidence fell well short. The Court also held that respondents' backpay claims were improperly certified under Rule 23(b)(2) where claims for monetary relief could not be certified under the rule. Accordingly, the judgment of the Court of Appeals was reversed.

Employees filed a proposed class action in state court, alleging violations of the minimum wage law. The employer removed to federal court. The district court found that the employer failed to show that the amount in controversy exceeds $5,000,000, as required for jurisdiction under the Class Action Fairness Act, 28 U.S.C. 1453(c)(1). The Seventh Circuit reversed and remanded. After the employer explained its calculations showing that the amount in controversy exceeded $5 million, in order to hold that there was no jurisdiction, the district court had to find that it was legally impossible for plaintiffs to recover that much. The employer's calculations regarding the accrual of the statutory penalty are a reasonable interpretation of the Illinois Minimum Wage Law statutory language.

Two-thousand unlicensed junior accountants brought a wage-and-hour class action against their employer, PricewaterhouseCoopers LLP ("PwC"), alleging, among other things, that PwC failed to pay them mandatory overtime under California law. At issue was whether unlicensed accountants in California were categorically ineligible, as a matter of law, to fall under the professional exemption and the administrative exemption from mandatory overtime. The court held that neither exemption was categorically inapplicable to unlicensed accountants as a matter of law and PwC established material fact questions on whether the accountants fell under either exemption. Therefore, the court reversed the district court's partial grant of summary judgment in favor of accountants and held that the exemption defenses must be resolved at trial.

Appellants appealed from an order granting summary judgment to appellee on a claim arising under the Worker Adjustment and Retraining Notification Act ("WARN"), 29 U.S.C. 21202, and dismissing without prejudice supplemental state law claims. Appellants alleged that appellee hired them as temporary workers in the midst of a strike and then summarily dismissed them at the strike's conclusion without providing the notice required under the WARN Act. The court held that the district court properly weighed the evidence when determining how to classify the striking workers and did not err in determining that appellants had failed to provided a viable legal theory on which to base its calculations. Moreover, though appellants complained that it was unrealistic to think that 32 striking workers would depart voluntarily, they produced no evidence supporting an alternative scenario. Therefore, appellants' conclusory statements on these issues failed to create a genuine issue of material fact and did not preclude the grant of summary judgment. The court also rejected appellants' claim that the district court erred in considering and rejecting only two of the four theories it proffered where the district court may not have addressed each theory they put forth, but it clearly rejected them all by concluding that the reduction in force was insufficient to satisfy the numerosity threshold. Therefore, the court agreed with the district court that the various theories offered by appellants failed, as a matter of law, to establish that a mass layoff occurred that would trigger notice requirements of the WARN Act. Accordingly, the judgment was affirmed.

Plaintiff, an employee of defendant, filed this action on behalf of herself and similarly-situated employees to recover wages and liquidated damages under the Fair Labor Standards Act of 1938 ("FLSA"), 29 U.S.C. 201, et. seq., for time spent donning and doffing protective gear during the workday at defendant's poultry processing plants. At issue was whether the district court properly held that the activities identified by the employees were compensable as "work" under the FLSA and that defendant's failure to pay the employees for these activities constituted a violation of the FLSA. The court agreed with the district court in substantial part and held that the time spent donning and doffing protective gear at the beginning and end of each workday was compensable as "work" under the FLSA. The court held, however, that based on the court's decision in Sepulveda v. Allen Family Foods, Inc., decided after the district court entered judgment in the present case, the court was required to hold that the mid-shift donning and doffing of protective gear at the employees' meal break was not compensable. The court additionally affirmed the district court's holding that defendant's violations of the FLSA were not "willful" and, accordingly, a two-year statute of limitations was applicable to the employees' claims for "back pay." Lastly, the court affirmed the district court's holding that defendant acted in good faith and its resulting decision declining to award liquidated damages to the employees.

Respondents, on behalf of beneficiaries of the CIGNA Corporation's ("CIGNA") Pension Plan, challenged the new plan's adoption, claiming that CIGNA's notice of the changes was improper, particularly because the new plan in certain respects provided them with less generous benefits. At issue was whether the district court applied the correct legal standard, namely, a "likely harm" standard, in determining that CIGNA's notice violations caused its employees sufficient injury to warrant legal relief. The Court held that although section 502(a)(1)(B) of the Employee Retirement Income Security Act of 1974 ("ERISA"), 29 U.S.C. 1022(a), 1024(b), 1054(h), did not give the district court authority to reform CIGNA's plan, relief was authorized by section 502(a)(3), which allowed a participant, beneficiary, or fiduciary "to obtain other appropriate relief" to redress violations of ERISA "or the [plan's] terms." The Court also held that, because section 502(a)(3) authorized "appropriate equitable relief" for violations of ERISA, the relevant standard of harm would depend on the equitable theory by which the district court provided relief. Therefore, the Court vacated and remanded for further proceedings.

In 1995 the city gave an examination for positions in its fire department and rated applicants on a scale between highly qualified and not qualified, based on scores. "Qualified" applicants were told that they were unlikely to be hired. From 1996 through 2001, the city hired random batches from the well-qualified pool. In 1997 a person in the qualified pool filed a charge of discrimination, claiming disparate impact on African-American applicants (42 U.S.C. 2000(e)). After receiving right-to-sue letters from the EEOC, applicants filed a class action in 1998. After a trial, the court rejected a business necessity defense and ruled in favor of the plaintiffs. On remand, after the Supreme Court held that most of the claims were timely, the Seventh Circuit affirmed. The city conceded that the cut-off score in the ranking system had a disparate impact, so each "batch" hiring had a similar impact. While hiring according to a list, perhaps hiring highest scorers first, might have served a business necessity, the random selection of batches amounted to repeated "use" of a tool that created disparate impact.

Petitioners, registered nurses ("RNs") employed in the region, filed a complaint alleging that various hospital owners and operators in the Albany-Schenectady-Troy metropolitan area had conspired to depress the compensation of RNs in violation of the Sherman Antitrust Act, 15 U.S.C. 1. A petition for leave to appeal was filed well outside the limitations period but filed within the fourteen days of the district court's denial of the motion to amend the class certification. At issue was whether such a denial constituted "an order granting or denying class-action certification" for purposes of Federal Rule of Civil Procedures 23(f). The court dismissed the petition and held that petitioners failed to timely petition with respect to an order reviewable pursuant to Rule 23(f) where an interlocutory appeal under Rule 23(f) could not properly be taken from an order denying amendment to a previous order granting class certification, at least when the motion to amend was filed fourteen days after the original order granting class certification.