Boone v. Amazon Services, LLC
1:21-cv-00241
| E.D. Cal. | Nov 7, 2024Background
- This case is a class and collective action brought by non-exempt Amazon employees in California, initially under the Fair Labor Standards Act (FLSA) and California law.
- Plaintiffs alleged that Amazon required employees to undergo mandatory COVID-19 screenings without pay, violating wage and hour laws.
- The suit consolidated with a similar action (Barrera v. Amazon) and also included a representative PAGA (Private Attorneys General Act) claim.
- The parties reached a $5.5 million non-reversionary settlement agreement after mediation, covering approximately 250,000 affected employees.
- No class members objected to the settlement, and only 16 opted out; the court found the notice and settlement administration proper and adequate.
- Plaintiffs also sought (and were awarded) attorneys’ fees, litigation costs, and enhancement payments for the class representatives.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Class certification under Rule 23 | Policy and effects affected all class members | Claims not suitable for class-wide resolution | Certification granted; Rule 23(a) and (b) met |
| Compensability of time spent at COVID screenings | Unpaid screening time is compensable under law | Time spent is de minimis or not compensable | Screening time held compensable |
| Fairness/adequacy of settlement under Rule 23(e) | Settlement is fair, reasonable, and adequate | No opposition | Settlement approved as fair, adequate, reasonable |
| Reasonableness of attorneys' fees (1/3 of fund) | Fees justified by risks, results, contingent nature | No opposition | Fees award of $1,833,333.33 granted |
Key Cases Cited
- Staton v. Boeing Co., 327 F.3d 938 (9th Cir. 2003) (sets standards for court approval of class action settlements)
- Hanlon v. Chrysler Corp., 150 F.3d 1011 (9th Cir. 1998) (articulates Rule 23 requirements for class certification and settlement fairness)
- Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338 (2011) (details commonality and rigorous analysis for class certification)
- Amchem Prods., Inc. v. Windsor, 521 U.S. 591 (1997) (discusses settlement-only class certifications)
- Powers v. Eichen, 229 F.3d 1249 (9th Cir. 2000) (establishes 25% benchmark for attorneys’ fees in class action common fund cases)
- Hensley v. Eckerhart, 461 U.S. 424 (1983) (result achieved as major factor for attorney fee awards)
- Arias v. Superior Ct., 95 Cal. Rptr. 3d 588 (Cal. 2009) (defines nature of PAGA actions and representative capacity)