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Jama v. GCA Services Group, Inc.
2:16-cv-00331
W.D. Wash.
Nov 3, 2016
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Background

  • 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)
Read the full case

Case Details

Case Name: Jama v. GCA Services Group, Inc.
Court Name: District Court, W.D. Washington
Date Published: Nov 3, 2016
Docket Number: 2:16-cv-00331
Court Abbreviation: W.D. Wash.