Carrillo v. Schneider Logistics, Inc.
2011 U.S. Dist. LEXIS 126167
| C.D. Cal. | 2011Background
- Plaintiffs filed a class action on Oct. 17, 2011 alleging FLSA and California wage-and-hour violations across three warehouses operated by Schneider Logistics and related entities.
- Defendants include Premier Warehousing Ventures, Rogers-Premier Unloading Services, and Impact Logistics; Schneider Logistics is challenged as to its connection to the Mira Loma facility.
- Plaintiffs sought a temporary restraining order and an order to show cause re: a preliminary injunction to compel immediate payroll recordkeeping and disclosure.
- The court applied Winter and related Ninth Circuit standards, concluding the TRO should issue based on likelihood of success, irreparable harm, and public interest.
- The court found plaintiffs likely to prevail on claims concerning itemized wage statements, proper hours-recording, and access to payroll/production records, including piece-rate disclosures.
- Defendants were ordered to immediately comply with recordkeeping and disclosure requirements and to show cause why a preliminary injunction should not be entered, with bond waived.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Likelihood of success on recordkeeping claims | Carrillo likely to prevail on §226(a)/(g) recordkeeping violations | Impact Logistics argues no injury and unresolved merits without full trial | Plaintiffs likely to prevail |
| Adequacy of wage statements | Statements are deficient for hours, piece rate, and formula disclosures | Statements provide some information and disputes require development | Likely to prevail on §226(a) claims |
| Irreparable harm absent relief | Failure to maintain records risks unpaid wages and confusion; wages are irreparable for low-wage workers | Defendants have attempted to provide information and will comply | Irreparable harm shown |
| Balance of equities and public interest | Compliance costs are nominal and in the public interest to enforce wage laws | Immediate compliance may be burdensome and prematurely resolved issues | Balance and public interest favor plaintiffs |
| Class certification for TRO | Provisional class should be certified to support TRO | No basis for provisional certification without full briefing | Denied without prejudice; may be renewed on noticed motion |
Key Cases Cited
- Winter v. Natural Res. Def. Council, Inc., 555 U.S. 7 (U.S. 2008) (establishes four-factor Winter test for injunctions)
- Stuhlbarg Int'l Sales Co. v. John D. Brushy & Co., 240 F.3d 832 (9th Cir. 2001) (clarifies likelihood of success/serious questions standard)
- American Trucking Ass'ns, Inc. v. City of Los Angeles, 559 F.3d 1046 (9th Cir. 2009) (Winter framework and equitable balance guidance)
- Cal. Pharms. Ass'n v. Maxwell-Jolly, 563 F.3d 847 (9th Cir. 2009) (emphasizes requirements for preliminary injunctions and public interest)
- Alliance for the Wild Rockies v. Cottrell, 632 F.3d 1127 (9th Cir. 2011) (serious questions merits alternative when other Winter elements met)
- Sierra On-Line, Inc. v. Phoenix Software, Inc., 739 F.2d 1415 (9th Cir. 1984) (defines 'serious questions' standard for injunctions)
- Morillion v. Royal Packing Co., 22 Cal.4th 575 (Cal. 2000) (definition of 'hours worked' and compensable time)
- Gould v. Maryland Sound Indus., Inc., 31 Cal.App.4th 1137 (Cal.App. 4th Dist. 1995) (public policy interest in prompt wage payment)
- Kerr's Catering Serv. v. Dirt, 57 Cal.2d 326 (Cal. 1962) (public interest in wage enforcement)
- Elliot v. Spherion Pac. Work, LLC, 572 F. Supp. 2d 1169 (C.D. Cal. 2008) (wage statements and recordkeeping relevance to damages)