Hollis v. Weatherford US LP
1:16-cv-00252
E.D. Cal.Jan 12, 2017Background
- Plaintiff Eric Hollis worked for Weatherford US LP as a Completion Specialist from March 2, 2012 to October 2, 2012 and was classified as exempt.
- Hollis sued under California wage-and-hour laws and asserted representative claims under the Private Attorney General Act (PAGA) for alleged unpaid wages and overtime.
- During discovery Hollis admitted he had previously signed a severance and release that he acknowledged released claims related to his employment, including PAGA claims.
- After deposition the parties negotiated a settlement: Hollis agreed to dismiss and release his PAGA claims; Weatherford agreed to waive all defense costs.
- Hollis moved for court approval of the PAGA settlement pursuant to Cal. Lab. Code § 2699.3; the court evaluated fairness given the plaintiff's admissions, the merits, and arm’s-length negotiations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court should approve the proposed settlement and release of PAGA claims | Hollis argued settlement was fair given small amount in controversy, the prior release, litigation risks, and that experienced counsel negotiated at arm’s length | Weatherford relied on the prior release and negotiated to obtain dismissal in exchange for waiving defense costs | Court approved the settlement as fair and reasonable, confirmed the release, dismissed the action with prejudice, and directed entry of judgment under the settlement |
Key Cases Cited
- Caliber Bodyworks, Inc. v. Superior Court, 134 Cal. App. 4th 365 (2005) (explains PAGA’s purpose as a supplement to state enforcement of labor laws)
- Arias v. Superior Court, 46 Cal. 4th 969 (2009) (PAGA plaintiff acts as proxy for the State in seeking civil penalties)
- Iskanian v. CLS Transp. Los Angeles, LLC, 59 Cal. 4th 348 (2014) (PAGA suits function as substitute for government enforcement and seek civil penalties)
- Villacres v. ABM Indus. Inc., 117 Cal. Rptr. 3d 398 (2010) (PAGA is limited to recovery of civil penalties)
- Nordstrom Commission Cases, 186 Cal. App. 4th 576 (2010) (courts have discretion to approve PAGA settlements where fair)