Miranda v. Coach, Inc.
3:14-cv-02031
N.D. Cal.May 22, 2017Background
- Two consolidated wage-and-hour actions against Coach alleging unpaid wages from off-the-clock security checks and improper overtime calculation; Ayala is the sole remaining named plaintiff representing CA sales associates from March 20, 2010 to May 3, 2016.
- Parties mediated and agreed to a revised non-reversionary $1.75 million settlement fund covering class payments, notice/admin costs, fees, PAGA payment, and a class representative enhancement; average class member payment ≈ $260.82.
- Court previously denied initial preliminary approval due to disclosure/notice concerns; parties executed an Addendum addressing deficiencies and Court granted preliminary approval thereafter.
- Notice was mailed to 4,598 members (≈3% undeliverable after forwarding efforts); emails sent to 1,957 members with minimal bounces; no objections and no opt-outs were received.
- The parties estimated gross potential recovery near $22 million, but after risk adjustments the litigation value was discounted to approximately $1.78 million, supporting settlement reasonableness.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Final approval of class settlement | Settlement provides meaningful relief, notice adequate, no objections | Settlement resolves claims and is reasonable given litigation risks | Granted: settlement finally approved |
| Adequacy of notice and class reaction | Notice complied with Rule 23; class reaction favorable (calls of support, no objections) | Adequacy and reaction support approval | Held adequate; lack of objections weighed in favor |
| Attorneys’ fees (25% of fund) | 25% of fund reflects percentage-of-fund and lodestar cross-check (lodestar $380,246; multiplier 1.15) | Fees should reflect risk, hours, and common-fund principles | Granted: $437,500 (25%) reasonable under percentage and lodestar cross-check |
| Costs and expenses ($50,175.24) | Requested costs are reasonable and necessary | Defendant did not oppose fee/costs request | Reduced: costs trimmed to $49,936.44 due to some personal meal expenses |
| Service (enhancement) award ($7,500 requested) | Ayala invested time/effort after co-plaintiff settled, warranting enhancement | Excessive awards to rep. discouraged; should be modest and justified | Reduced: awarded $1,500 based on effort and Ninth Circuit guidance |
Key Cases Cited
- Nat’l Rural Telecomms. Coop. v. DIRECTV, Inc., 221 F.R.D. 523 (C.D. Cal. 2004) (absence of class objections supports settlement fairness)
- Churchill Vill., LLC v. Gen. Elec., 361 F.3d 566 (9th Cir. 2004) (class reaction is a factor in settlement evaluation)
- In re Online DVD-Rental Antitrust Litig., 779 F.3d 934 (9th Cir. 2015) (percentage-of-the-fund method acceptable for common-fund fee awards)
- Vizcaino v. Microsoft Corp., 290 F.3d 1043 (9th Cir. 2002) (lodestar cross-check and multipliers to account for risk are appropriate)
- Staton v. Boeing Co., 327 F.3d 938 (9th Cir. 2003) (factors for awarding service enhancements to class representatives)
