Rojas-Cifuentes v. ACX Pacific Northwest Inc., 2:14-cv-00697

Plaintiff Miguel Rojas‑Cifuentes sued ACX Pacific Northwest and related defendants in a wage‑and‑hour action; he worked for defendants until May 2013 and filed a First Amended Complaint (FAC) in May 2014.
During discovery in 2016 plaintiff identified deficiencies in the FAC and moved for leave to file a Second Amended Complaint (SAC) to add: (1) meal‑period claims (Cal. Lab. Code § 512/§ 226.7), (2) expanded allegations about unpaid time (including off‑the‑clock work and time‑rounding), and (3) related UCL predicates.
Defendants opposed, arguing (a) the meal‑period claims are time‑barred and do not relate back, (b) the added rounding/theory allegations are futile because rounding is lawful, and (c) plaintiff unduly delayed and amendment would prejudice defendants.
The court applied Rule 15(a) (liberal leave to amend) and the Rule 12(b)(6)/Iqbal plausibility standard in evaluating futility and relation‑back under Fed. R. Civ. P. 15 and applicable state/federal relation‑back tests.
The court concluded the meal‑period allegations were already fairly pled in the FAC (so the added meal claims relate back), the added rounding and unpaid‑time allegations were plausible, and delay/prejudice did not warrant denial because discovery and scheduling are ongoing.
The court granted leave to amend (SAC due within five days; defendants to respond within 20 days) and imposed monetary sanctions on both parties’ counsel for exceeding the court’s page limits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether meal‑period claims are time‑barred or relate back	Meal claims track facts already alleged (failure to provide meal breaks) and thus relate back so not time‑barred	Meal claims are outside the 3‑year statute (last work May 2013) and cannot relate back	Granted: meal‑period allegations relate back to FAC because defendants had adequate notice; claim is not futile
Whether expanded unpaid‑time allegations (off‑the‑clock, donning/doffing, rounding) are futile	New factual detail elaborates existing claims and will be proven with same core evidence	New rounding theory is a different theory and rounding policies are lawful; thus futile	Granted: allegations are plausible under Iqbal and relate to the same core facts; not futile at pleading stage
Whether plaintiff unduly delayed or would prejudice defendants	Delay resulted from discovery revealing deficiencies; no scheduling order or trial date; defendants have records and time to respond	Two‑plus year delay; amendment forces re‑investigation and increased burden	Granted: delay alone insufficient; discovery ongoing and defendants had notice; prejudice not shown to justify denial
Whether sanctions are warranted for exceeding page limits	N/A (court addressed procedural rule violations)	N/A	Court imposed monetary sanctions ($300 on defense counsel; $700 on plaintiff's counsel) and disregarded arguments beyond page limits

DCD Programs, Ltd. v. Leighton, 833 F.2d 183 (9th Cir. 1987) (leave to amend lies within trial court discretion)
U.S. v. Webb, 655 F.2d 977 (9th Cir. 1981) (Rule 15 should be applied with extreme liberality)
Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard for pleading)
Cortez v. Purolator Air Filtration Prod. Co., 23 Cal.4th 163 (Cal. 2000) (UCL claims may borrow a longer limitations period but do not extend limitations for the underlying statutory claim)
Brinker Rest. Corp. v. Superior Court, 53 Cal.4th 1004 (Cal. 2012) (employer obligations for meal/rest periods)
See’s Candy Shops, Inc. v. Superior Court, 210 Cal.App.4th 889 (Cal. Ct. App. 2012) (time‑rounding permissible if neutral and not causing underpayment)
Williams v. Boeing Co., 517 F.3d 1120 (9th Cir. 2008) (relation‑back analysis where new theory depended on different facts)
ASARCO, LLC v. Union Pac. R.R. Co., 765 F.3d 999 (9th Cir. 2014) (relation back requires common core of operative facts)