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United States Court of Appeals for the Ninth Circuit
November 19, 2020, Argued and Submitted, Pasadena, California; May 28, 2021, Filed
BUMATAY, Circuit Judge:
Roderick Magadia worked sales for Walmart for eight years. After the company let him go, Magadia filed a class action suit against Wal-Mart Associates, Inc., and Walmart, Inc., (collectively, "Walmart"), alleging three violations of California Labor Code's wage-statement [*5] and meal-break requirements. First, Magadia alleged that Walmart didn't provide adequate pay rate information on its wage statements. See Cal. Lab. Code § 226(a)(9). Next, he claimed that Walmart failed to furnish the pay-period dates with his last paycheck. See id. § 226(a)(6). Finally, he asserted that Walmart didn't pay adequate compensation for missed meal breaks. See id. § 226.7(c). ] Magadia sought penalties for these claims under California's Private Attorneys General Act ("PAGA"), which authorizes an aggrieved employee to recover penalties for Labor Code violations on behalf of the government and other employees. See id. § 2699.
The district court at first certified classes corresponding to each of Magadia's three claims. After summary judgment and a bench trial, the district court found that Magadia in fact suffered no meal-break violation and decertified that class. Even so, the district court allowed Magadia to still seek PAGA penalties on that claim based on violations incurred by other Walmart employees. The district court then ruled against Walmart on the three claims and awarded Magadia and the two remaining classes over $100 million in damages and penalties.
On appeal, we hold that Magadia lacked standing to bring the meal-break claim because he did not suffer injury himself. [*6] As for the two wage-statement claims, we hold that Magadia had standing but conclude that Walmart did not breach California law.
Walmart pays its employees and issues wage statements every two weeks. Walmart also voluntarily offers quarterly "MyShare" bonuses to high-performing employees. Walmart reports these quarterly bonuses on qualifying employees' wage statements as "MYSHARE INCT."
Full case includes Shepard's, Headnotes, Legal Analytics from Lex Machina, and more.
2021 U.S. App. LEXIS 16070 *; __ F.3d __; 2021 WL 2176584
RODERICK MAGADIA, individually and on behalf of all those similarly situated, Plaintiff-Appellee, v. WAL-MART ASSOCIATES, INC., a Delaware corporation; WALMART INC., a Delaware corporation, Defendants-Appellants.
Subsequent History: As Corrected June 1, 2021.
Prior History: [*1] Appeal from the United States District Court for the Northern District of California. D.C. No. 5:17-cv-00062-LHK. Lucy H. Koh, District Judge, Presiding.
qui tam, pay period, overtime, employees, hourly rate, district court, meal-break, aggrieved employee, calculated, bonus, overtime pay, violations, concrete, simplified, damages, adjusted, semimonthly, furnish, rights, hours worked, wage-statement, corresponding, intervene, bonuses, partial, courts, meal
Labor & Employment Law, Remedies, Damages, Liquidated Damages, Wage & Hour Laws, Private Suits, Business & Corporate Compliance, Scope & Definitions, Overtime & Work Periods, Regular Rate, Labor & Employment Law, Wage Payments, Backpay, Recordkeeping Requirements, Civil Procedure, Appeals, Standards of Review, Clearly Erroneous Review, De Novo Review, Questions of Fact & Law, Justiciability, Standing, Injury in Fact, Constitutional Law, Case or Controversy, Elements, False Claims Act, Qui Tam Actions, Parties, Real Party in Interest, Assignees, Governments, Federal Government, Claims By & Against, Equity, Maxims, Assignees Principle, Class Actions, Retaliation, Statutory Application, False Claims Act, Remedies, Public Contracts Law, Voiding Contracts, Fraud & Whistleblowing, State & Territorial Governments, Antitrust & Trade Law, Trade Practices & Unfair Competition, State Regulation, Scope, Legislation, Statutory Remedies & Rights, The Judiciary, Standing, Legislatures, Personal Stake, Special Proceedings, Class Actions, Class Members, Interpretation