Rudy Gilbert Padilla v. Ames Construction, Inc.
2:25-cv-03522
C.D. Cal.Jun 20, 2025Background
- Plaintiff filed a class action in Los Angeles Superior Court against his employer, alleging various California Labor Code violations (including minimum wage, overtime, meal and rest breaks, wage statements, and business expense reimbursement) and unfair business practices.
- Plaintiff later amended the complaint to add a claim under the Private Attorneys General Act (PAGA).
- Defendant removed the case to federal court, arguing the claims are preempted by § 301 of the Labor Management Relations Act (LMRA) because of a controlling Collective Bargaining Agreement (CBA).
- Plaintiff moved to remand back to state court; defendant moved for judgment on the pleadings, arguing all claims were preempted and must be dismissed.
- The dispute centers on whether plaintiff’s claims are preempted by federal labor law because they depend on or are covered by the CBA.
- The court considered both motions together, analyzing the preemption question claim-by-claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether CBA applies to Plaintiff | Defendant failed to show all class members covered by CBA | CBA applies to all relevant positions, both union and non-union | CBA covers Plaintiff and class; applies here |
| Timeliness of Removal | Defendant's removal was untimely | Removal timely since removability not apparent in initial complaint | Removal was timely under § 1446(b) |
| LMRA Preemption of Claims | Claims arise from non-negotiable state rights, not CBA terms | Claims derive from CBA; statutory exemptions apply making CBA controlling | Most claims preempted (except minimum wage, expenses) |
| Remand to State Court | Federal court lacks jurisdiction due to state-law basis | Preemption creates federal jurisdiction | Motion to remand denied |
| Judgment on Preempted Claims | Claims not preempted so not dismissible | Preempted claims must be dismissed | Preempted claims dismissed; leave to amend granted |
Key Cases Cited
- Caterpillar, Inc. v. Williams, 482 U.S. 386 (well-pleaded complaint rule for federal question jurisdiction)
- Allis-Chalmers Corp. v. Lueck, 471 U.S. 202 (authority of federal courts under § 301 to create federal common law for labor contracts)
- Teamsters v. Lucas Flour Co., 369 U.S. 95 (uniform federal law governing CBA disputes)
- United Mine Workers of Am. v. Gibbs, 383 U.S. 715 (supplemental jurisdiction over related state claims)
- Hal Roach Studios, Inc. v. Richard Feiner & Co., 896 F.2d 1542 (standards for judgment on the pleadings)