Schroeder v. Host Int'l, Inc.

Schroeder v. Host Int'l, Inc.

Opinion

Civil Minutes — General

Proceedings: (In Chambers) Order Remanding Case To State Court (JS-6)

I. BACKGROUND

This is a wage and hour putative class action for California Labor Code violations Plaintiff Karla Schroeder encountered during her two days of employment with Defendant Host International, Inc. in 2019. See Compl., ECF No. 1-1.¹ Plaintiff originally filed this case on September 30, 2020 in Los Angeles County Superior Court and sought certification of two classes for a total of nine class claims. She also brought one claim under California's Private Attorney General Act ("PAGA"), Cal. Lab. Code § 2698, and one individual claim. Defendant removed the case to federal court on January 15, 2021. ECF No. 1. On July 26, 2021, Plaintiff moved for class certification, ECF No. 16, and [*2]  on August 30, 2021, Defendant moved for judgment on the pleadings on some of Plaintiff's individual claims, ECF No. 22.

Defendant first raised these jurisdictional concerns in response to the motion for class certification, arguing that class certification should be denied because Plaintiff lacked Article III standing for many of her claims. Def. Class Certification Opp'n 9-10, ECF No. 18. Plaintiff did not address whether she had standing in her reply brief. Pl. Class Certification Reply, ECF No. 26.

The Court's review of the briefing for both motions confirmed that Defendant's concerns about standing were warranted and uncovered additional jurisdictional concerns under both Article III and the Class Action Fairness Act of 2005 ("CAFA"). The Court was concerned that the Complaint contained virtually no factual details regarding Plaintiff's case, that Plaintiff's conclusory allegations of injury were in many instances proven demonstrably false by undisputed evidence, and that many of her claims were related to work done after she resigned from her job. The Court raised its concerns with the parties sua sponte in a December 13, 2021 order. ECF No. 31. The Court asked the parties to submit briefing and evidence on [*3]  the jurisdictional issues addressing six questions:

1. What is Plaintiff's Article III injury for each claim?

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