Lou v. MA Laboratories, Inc
3:12-cv-05409
| N.D. Cal. | Mar 14, 2014Background
- Lou filed an Oct 2012 putative FLSA collective and Rule 23 class action alleging a company-wide overtime-denial scheme at Ma Laboratories.
- Feb 2013, Feng filed a consent-to-join form; April 2013, Yi, De La Madrid Nickel, Ruiz Rodriguez, and Shigemitsu joined; July 2013 Nim and Beer joined; seven opt-ins became party-plaintiffs.
- Aug 2013 order allowed first amended complaint and extended discovery; six more joined; ten individuals became party-plaintiffs.
- Feb 2014, named-plaintiffs reached settlement in principle with four, but six opt-ins remained unresolved; deadlines stayed pending proper FRCP 41 procedures.
- Mar 14, 2014 hearing addressed settlement status and opt-ins; court declined to approve non-final settlements and ordered trial to proceed; opt-ins retained status as FLSA party-plaintiffs; and rulings on defenses and disclosures issued.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether opt-in consent-for-join forms made co‑workers party-plaintiffs. | Lou and co‑plaintiffs contend opt-ins became party-plaintiffs. | Ma argued opt-ins require amendment and could be dismissed without prejudice. | Opt-ins became party-plaintiffs and may proceed on FLSA claim. |
| Whether the court should enjoin enforcement of non-final settlements. | Plaintiffs seek injunction to prevent unilateral settlement enforcement. | No need for court vetting of individual settlements. | Denied; no final settlement or court-reviewed approval present. |
| Whether deadlines must continue despite discussions of settlements. | Deadlines remain in place; settlement in principle not finalized. | Settlement discussions could affect timing; deadlines should be treated flexibly. | All existing deadlines and scheduled trial proceed. |
| Whether time-barred opt-ins may be subjected to defenses or amended pleadings. | Opt-ins’ status should not prejudice trial readiness. | Defenses (time-bar) may be raised via amendments. | Defendant may amend to assert time-bar as to three opt-ins; disclosures updated. |
Key Cases Cited
- Hoffmann-La Roche Inc. v. Sperling, 493 U.S. 165 (Supreme Court, 1989) (court management of joinder in FLSA actions)
- Genesis Healthcare Corp. v. Symczyk, 133 S. Ct. 1523 (Supreme Court, 2013) (proceeding to join parties in a collective action under FLSA)
- Lynn’s Food Stores, Inc. v. U.S. Dept. of Labor, 679 F.2d 1350 (11th Cir., 1982) (court scrutiny for fairness of settlements in wage actions)
- Barrentine v. Arkansas–Best Freight System, 450 U.S. 728 (Supreme Court, 1981) (wage-hour protections and reasonable interpretation of FLSA)