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Miranda v. Coach, Inc.
3:14-cv-02031
N.D. Cal.
May 22, 2017
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Background

  • 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)
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Case Details

Case Name: Miranda v. Coach, Inc.
Court Name: District Court, N.D. California
Date Published: May 22, 2017
Docket Number: 3:14-cv-02031
Court Abbreviation: N.D. Cal.