Jama v. GCA Services Group, Inc.
2:16-cv-00331
W.D. Wash.Nov 3, 2016Background
- Plaintiffs (GCA employees) filed a class action alleging GCA failed to pay SeaTac's $15/hr minimum under SeaTac Municipal Code §7.45 after Jan 1, 2014.
- GCA had a contract to shuttle Avis rental cars among Seattle-area locations, including Sea-Tac airport; employees occasionally assisted customers and sometimes moved luggage as ancillary to shuttling.
- The ordinance defines "Transportation Employer" by listing specific services (e.g., baggage handling, ground transportation management, customer service) and a 25-employee threshold.
- Plaintiffs argued GCA falls within the ordinance because it performs baggage handling, ground transportation management, and customer service at the airport.
- The parties stipulated facts; dispute centered on statutory construction of the listed terms in §7.45.010(M).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether GCA is a "baggage handling" employer | Occasional lifting/moving of luggage during shuttles qualifies as baggage handling | "Baggage handling" means a business that provides baggage-handling services as its function, not incidental tasks | Court: Not baggage handling — the term refers to businesses whose primary service is baggage handling, not incidental acts |
| Whether GCA provides "ground transportation management" | Managing movement/distribution of Avis rental cars is ground transportation management | Term refers to managing the overall flow/system of ground transportation, not a single-mode operator like a rental-car shuttle | Court: Not ground transportation management — rental-car operations are distinct and covered separately in §M(2) |
| Whether GCA provides "customer service" within the meaning of the ordinance | Employee assistance to customers at airport constitutes customer service | "Customer service" means providing that service as part of the business operation, not occasional assistance | Court: Not customer service for ordinance purposes — incidental assistance does not convert shuttling into covered customer-service operations |
| Whether state-court certification was necessary | Plaintiffs requested certification if ambiguity existed | Defendant opposed certification; court found state guidance unnecessary | Court: Declined to certify to Washington Supreme Court; statutory language and rules of construction were clear |
Key Cases Cited
- In re Schneider, 173 Wn.2d 353 (court's purpose is to ascertain legislative intent)
- Tracfone Wireless, Inc. v. Dep’t of Revenue, 170 Wn.2d 273 (plain meaning controls absent ambiguity)
- Dep’t of Ecology v. Campbell & Gwinn, LLC, 146 Wn.2d 1 (use related statutes in construction; plain meaning rule)
- Cerrillo v. Esparza, 158 Wn.2d 194 (if multiple reasonable interpretations exist, consult construction rules and legislative history)
- Anthis v. Copland, 173 Wn.2d 752 (statutory interpretation principles)
- Roe v. TeleTech Customer Care Mgmt. (Colo.), LLC, 152 Wn. App. 388 (voter initiatives follow statutory construction rules)
- Amalgamated Transit Union Local 587 v. State, 142 Wn.2d 183 (determine collective intent of voters for initiatives)
