Lisa A. Wadley v. AMEC Foster Wheeler USA Corporation
5:23-cv-00224
C.D. Cal.Jan 9, 2024Background
- Lisa Wadley, a former biologist at WSP USA Environment and Infrastructure Inc., filed a class action in Riverside Superior Court alleging various California labor law violations.
- She represented two groups: non-exempt hourly employees and employees allegedly misclassified as exempt.
- Defendants removed the case to federal court under the Class Action Fairness Act (CAFA), claiming jurisdiction based on class size, diversity, and amount in controversy.
- Wadley moved to remand the case, arguing the amount in controversy did not exceed the $5 million CAFA threshold.
- Defendants recalculated the amount in controversy in opposition, modifying their earlier arguments.
- Judge Sunshine S. Sykes granted the motion to remand, sending the case back to state court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| CAFA Amount in Controversy Exceeded $5 Million? | Amount in controversy does not meet $5M; defendant's estimates unsubstantiated | Amount in controversy exceeds $5M based on damages calculated for non-exempt and misclassified employees | Defendant failed to prove $5M; remand granted |
| Scope of Class Action Damages | Damages should be limited; no evidence all exempt employees misclassified | All full-time non-exempt and all exempt employees included in calculation | Insufficient evidence; damages limited to non-exempt full-time employees |
| Claims for Overtime Damages by Misclassified Exempts | No plausible basis all exempts misclassified | Assumption that all full-time exempts misclassified, claim over $2.2M damages | No support or evidence for defendant’s assumptions |
| Calculation of Damages for Other Wage Claims | Defendant's figures are inflated | Damages for meal/rest violations, waiting time, wage statements push past threshold | Even if accepted, figures (plus fees) < $5M |
Key Cases Cited
- Dart Cherokee Basin Operating Co., LLC v. Owens, 574 U.S. 81 (2014) (describes pleading standards for removal under CAFA)
- Salter v. Quality Carriers, 974 F.3d 959 (9th Cir. 2020) (explains facial vs. factual attacks on CAFA jurisdiction)
- Ibarra v. Manheim Investments, Inc., 775 F.3d 1193 (9th Cir. 2015) (burden of proof on defendant to show CAFA threshold met)