Izzio v. Century Golf Partners Management, L.P.
670 F. App'x 348
5th Cir.2016Background
- Plaintiffs sued Century Golf under the FLSA and New York labor law for practices at four New York catering facilities; parties reached a settlement and sought class certification for settlement purposes.
- The district court certified settlement classes and approved the settlement with minimal oral and written explanation.
- Objectors Jillian Brana and Anthony Metzger appealed, arguing the district court failed to properly analyze Rule 23(a) factors and that certification was therefore improper; they also challenged settlement approval (court did not reach the settlement-approval argument).
- Objectors pointed to the settling parties’ admissions that the four facilities changed practices at different times and in different ways, potentially undermining commonality and creating individualized inquiries.
- The Fifth Circuit reviewed whether the district court conducted the required rigorous Rule 23(a) analysis and whether commonality was satisfied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court properly certified settlement classes under Rule 23(a) | Certifying was improper because factual and temporal differences across facilities defeat commonality and require individualized analyses | Parties had stipulated to certification for settlement; district court treated certification as satisfied | Vacated certification order and remanded for a rigorous Rule 23(a) analysis |
| Whether the district court conducted a sufficiently rigorous Rule 23(a) inquiry | The district court failed to analyze numerosity, commonality, typicality, adequacy with reasons; mere assent is insufficient | District court relied on parties’ agreement and brief statements at hearing | Court held the district court did not perform the required rigorous analysis and must make explicit Rule 23 findings |
Key Cases Cited
- Pederson v. La. State Univ., 213 F.3d 858 (5th Cir. 2000) (appellate review standard for class certification is abuse of discretion)
- Ibe v. Jones, 836 F.3d 516 (5th Cir. 2016) (illustrates a proper rigorous Rule 23(a) analysis)
- Califano v. Yamasaki, 442 U.S. 682 (U.S. 1979) (Rule 23 governs class action exception to individual litigation rule)
- Unger v. Amedisys, Inc., 401 F.3d 316 (5th Cir. 2005) (district courts must conduct rigorous Rule 23 review due to due-process concerns)
- Stirman v. Exxon Corp., 280 F.3d 554 (5th Cir. 2002) (court cannot rely on parties’ stipulation; conclusory statements are insufficient for certification)