3:19-cv-01353
N.D. Cal.Aug 5, 2020Background
- Plaintiffs (named California employees) sued Stellar Management Group VII, Stellar Management Group, Inc. and The Vincit Company under the FLSA (collective) and California law (class for CA workers); defendants are Tennessee-based.
- The FAC alleges uniform, nationwide pay policies that underpaid hourly non-exempt workers and omitted accurate wage statements; plaintiffs seek an FLSA collective covering nationwide hourly, non-exempt employees.
- Several putative opt-in collective members joined after filing, including at least one who worked in Lufkin, Texas.
- Defendants Stellar Inc. and Vincit LLC previously moved to dismiss; the court found no general jurisdiction but held specific jurisdiction as to California-based plaintiffs and denied renewed motions to dismiss.
- Defendants moved to dismiss claims of out-of-state opt-ins for lack of personal jurisdiction, arguing Bristol-Myers Squibb precludes jurisdiction over plaintiffs without connections to California.
- The court denied the motion: it held Bristol-Myers does not strip federal courts of jurisdiction over FLSA collective claims and exercised pendent personal jurisdiction over out-of-state opt-in claims because they arise from a common nucleus of operative facts with the California plaintiffs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Bristol-Myers limits a federal court’s personal jurisdiction over out-of-state opt-in FLSA plaintiffs | Bristol-Myers does not apply to federal courts hearing federal-law claims; federalism concerns are absent. | Bristol-Myers bars jurisdiction for plaintiffs who lack contacts with the forum state. | Court held Bristol-Myers does not divest federal courts of jurisdiction over FLSA collective claims. |
| Whether the court may decide personal-jurisdiction for opt-ins before collective certification | Plaintiffs did not oppose early resolution; at least one opt-in already joined, making the issue ripe. | Defendants’ jurisdictional challenge was timely and appropriate despite pending certification. | Court allowed the Rule 12(b)(2) challenge and ruled on it prior to certification. |
| Whether the court can exercise pendent personal jurisdiction over out-of-state opt-ins | Opt-in claims arise from the same nationwide, uniform employment policy — common nucleus of operative facts. | Defendants argued each opt-in lacks an independent forum connection and Bristol-Myers forbids jurisdiction. | Court exercised pendent jurisdiction over out-of-state opt-ins to promote efficiency and avoid piecemeal litigation. |
Key Cases Cited
- Bristol-Myers Squibb Co. v. Superior Court, 137 S. Ct. 1773 (2017) (Supreme Court holding California courts lacked personal jurisdiction over nonresident plaintiffs with no connection to forum)
- Int’l Shoe Co. v. Washington, 326 U.S. 310 (1945) (establishing minimum contacts due process test for specific jurisdiction)
- Dole Food Co. v. Watts, 303 F.3d 1104 (9th Cir. 2002) (articulating Ninth Circuit specific-jurisdiction framework aligning state-law and federal due-process analysis)
- Action Embroidery Corp. v. Atl. Embroidery, Inc., 368 F.3d 1174 (9th Cir. 2004) (permitting pendent personal jurisdiction where claims share a common nucleus of operative facts)
- Campbell v. City of Los Angeles, 903 F.3d 1090 (9th Cir. 2018) (describing FLSA collective procedure and that opt-in plaintiffs obtain party status)
- Sloan v. Gen. Motors LLC, 287 F. Supp. 3d 840 (N.D. Cal. 2018) (explaining Bristol-Myers does not apply to federal courts and endorsing pendent jurisdiction over out-of-state plaintiffs in federal-question cases)
- Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (2011) (corporate forum contacts insufficient for specific jurisdiction over unrelated claims)
