Jesus Leyva v. Medlin Industries Inc
716 F.3d 510
| 9th Cir. | 2013Background
- Leyva seeks class certification for about 538 Medline warehouse employees in California; claims include rounding start times in 29-minute increments causing unpaid work; alleges nondiscretionary bonuses were improperly excluded from overtime; seeks penalties and wage-statement damages under California law; district court denied certification under Rule 23(b)(3) for lack of predominance and manageability; the panel reverses and remands for certification.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Predominance of common questions | Damages are calculable via common liability questions. | Damages are highly individualized. | Common questions predominate; damages alone do not defeat certification. |
| Superiority of class adjudication | Class action is the superior method given small individual recoveries. | Manageability and alternative methods preclude superiority. | Class action is superior; manageability concerns overstated. |
| Correct legal standard applied by court | Court used wrong standard by focusing on damages isolation. | Court correctly balanced Rule 23 factors. | District court abused discretion by misapplying standard. |
| Feasibility of damages calculation | Payroll/database data can calculate damages for all members. | Individualized damages prevent class relief. | Damages feasible to calculate via common method; does not defeat class. |
Key Cases Cited
- Wal-Mart Stores, Inc. v. Dukes, 131 S. Ct. 2541 (2011) (commonality requires a common contention; no need to isolate damages to defeat class)
- Behrend, LLC v. Behrend, 133 S. Ct. 1426 (2013) (damages model must measure damages attributable to the theory of liability)
- Brinker Rest. Corp. v. Superior Court, 273 P.3d 513 (Cal. 2012) (damages determinations are common in wage actions; not fatal to class)
- Comcast Corp. v. Behrend, 133 S. Ct. 1426 (2013) (damages must be tied to the theory of liability; appropriate model needed)
- Hinkson, United States v., 585 F.3d 1247 (9th Cir. 2009) (two-step abuse-of-discretion standard for certification rulings)
- Yokoyama v. Midland Nat’l Life Ins. Co., 594 F.3d 1087 (9th Cir. 2010) (damages calculations alone do not defeat class certification)
- Blackie v. Barrack, 524 F.2d 891 (9th Cir. 1975) (damages are typically individualized but do not defeat class certification)
- Cooter & Gell v. Hartmarx Corp., 496 U.S. 384 (1990) (district court abuses if based on erroneous view of law)
- Las Vegas Sands, Inc., 244 F.3d 1152 (9th Cir. 2001) (tribune manageability factors in Rule 23(b)(3) analysis)