Daniel Figueroa v. AutoZoners, LLC
2:18-cv-01106
C.D. Cal.Jan 31, 2019Background
- Plaintiff Daniel Figueroa sued AutoZoners, LLC in Feb 2018 asserting multiple California Labor Code and FEHA claims, but later dismissed all claims except a PAGA count.
- Defendant moved originally to compel arbitration and alternatively to stay or dismiss; after Plaintiff narrowed the case, Defendant filed a Revised Motion to Stay pending resolution of Alvarez v. AutoZone (filed Dec. 1, 2014).
- Alvarez is an earlier-filed action in the Central District alleging similar employer–employee wage-and-hour violations against related AutoZone entities.
- Defendant argued the First-to-File (comity) rule requires a stay because the earlier suit shares parties/interests and overlapping factual issues.
- The court evaluated the three First-to-File factors: similarity of parties (substantial, not identical), chronology (Alvarez first-filed), and similarity of issues (substantial factual overlap, including PAGA-related claims).
- The court granted Defendant’s Revised Motion and stayed the entire action pending resolution of Alvarez; hearings were vacated and periodic status reports were ordered.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the First-to-File rule applies | Figueroa argued the suits do not have identical parties or identical claims, so stay is improper | Alvarez is earlier-filed and involves substantially similar parties/interests and overlapping factual issues, so the later action should be stayed | First-to-File applies; stay granted |
| Similarity of parties requirement | Exact party identity required to invoke comity | Substantial similarity of parties or interests suffices; AutoZoners and AutoZone, Inc. share defense interests | Parties deemed substantially similar; favors stay |
| Similarity of issues requirement | Lack of identical claims (only PAGA remains) defeats comity | Issues need not be identical; substantial factual overlap (wage claims, employer–employee relationship) is enough | Issues substantially overlap; favors stay |
| Remedy available under First-to-File | N/A | Court may stay, transfer, or dismiss later-filed action to avoid duplication | Court exercised discretion to stay the case pending Alvarez |
Key Cases Cited
- Pacesetter Sys., Inc. v. Medtronic Inc., 678 F.2d 93 (9th Cir. 1982) (articulates First-to-File/comity doctrine)
- Alltrade, Inc. v. Uniweld Prods., Inc., 946 F.2d 622 (9th Cir. 1991) (later-filed court may stay, transfer, or dismiss under First-to-File)
- Kohn Law Grp., Inc. v. Auto Parts Mfg. Miss., Inc., 787 F.3d 1237 (9th Cir. 2015) (lists factors for applying First-to-File rule)
- Wallerstein v. Dole Fresh Vegetables, 967 F. Supp. 2d 1289 (N.D. Cal. 2013) (First-to-File rule not limited to different districts)
- Barapind v. Reno, 72 F. Supp. 2d 1132 (E.D. Cal. 1999) (parties representing same interests can render second action duplicative)