Lazares v. Shopify (USA), Inc.
4:24-cv-07125
N.D. Cal.May 14, 2025Background
- Matthew Lazares, a former commissioned sales employee, brought a putative class action against Shopify (USA), Inc., alleging misclassification and Labor Code violations under California law.
- Lazares claimed misclassified employees were denied overtime, proper meal/rest breaks, timely pay, and forced to work without required days off; he also alleged unlawful commission and non-compete/confidentiality agreements.
- Lazares sought relief under the California Unfair Competition Law (UCL) for equitable remedies (including restitution and disgorgement) and injunctive relief.
- Shopify previously moved for, and was granted, judgment on the pleadings on the UCL claim; Lazares filed a second amended complaint (SAC).
- Shopify again moved for judgment on the pleadings (Rule 12(c)), arguing the SAC failed to establish entitlement to equitable remedies or standing for injunctive relief under UCL.
- The court reviewed both parties’ arguments, referencing Ninth Circuit precedent and questioning the accuracy of several citations in plaintiff’s briefing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Adequacy of legal remedies for UCL relief | Legal remedies not adequate because the statute of limitations for Labor Code is shorter than UCL | Statute of limitations doesn’t make a legal remedy inadequate | Difference in statute of limitations doesn't render legal remedy inadequate |
| Equitable relief for §16600.1 non-compete claim | Legal remedies inadequate because UCL is meant to enforce §16600.1 rights | Plaintiff has access to damages under §16600.5(e)(1) | Actual damages under the statute are available and not shown to be inadequate |
| Standing for prospective injunctive relief | Needs an injunction to stop ongoing/future harms from unlawful employer conduct | Plaintiff, as a former employee, faces no imminent future injury | Plaintiff has not shown real and immediate threat or economic injury for standing |
| Leave to amend | Requests further leave to amend SAC to fix defects | Re-amendment would be futile, no new facts proposed | Leave to amend denied; dismissal without prejudice to refiling in state court |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (Pleading standard of plausibility for federal complaints)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (Facial plausibility required to state a claim)
- Guzman v. Polaris Indus., 49 F.4th 1308 (Statute of limitations does not render legal remedy inadequate for UCL equitable relief)
- Kwikset Corp. v. Superior Court, 51 Cal. 4th 310 (UCL standing requires economic injury and causation)
- McKesson HBOC, Inc. v. New York State Common Ret. Fund, Inc., 339 F.3d 1087 (Availability of legal remedies is dispositive even if plaintiff did not pursue them)
- Chapman v. Pier 1 Imports (U.S.) Inc., 631 F.3d 939 (Article III standing for injunctive relief requires real and immediate prospect of future harm)
- Lujan v. Defs. of Wildlife, 504 U.S. 555 (Article III standing requires concrete and particularized injury)