Starbucks Corp. v. Superior Court

Summary

The California Court of Appeal considered Starbucks Corporation's petition for a writ of mandate challenging the denial of its motion for summary judgment in a class action concerning an employment application question about criminal convictions. The court held that the placement of California-specific disclaimer language created a potential ambiguity but concluded that the named plaintiffs lacked the required connection to the statutory protections because they had no marijuana-related convictions and understood the disclaimer. The opinion addresses Labor Code sections 432.7 and 432.8, statutory damages, standing, and the requirement that plaintiffs be aggrieved persons within the class protected by the statute.

Holdings

1. The application could not be held compliant as a matter of law because the California disclaimer was placed at the end of a lengthy paragraph containing multiple unrelated state and federal disclaimers, creating a potential ambiguity for a reasonable California job applicant.
2. Plaintiffs who had no marijuana-related convictions and suffered no injury of the type the statutes were designed to prevent were not within the protected class and were not automatically entitled to recover $200 merely because they completed an application containing the challenged question.
3. The deposition testimony of Lords and Yeung was dispositive as to them because both understood that the application did not require disclosure of marijuana convictions more than two years old and offered no contradictory extrinsic evidence.
4. Writ relief was appropriate because appeal from a later judgment would provide an inadequate remedy, Starbucks faced potentially irreparable pressure from the class action's substantial exposure, and the matter was of widespread interest.

Questions Presented

1. Whether the placement of Starbucks's California disclaimer rendered the employment application legally ambiguous under California Labor Code sections 432.7 and 432.8.
2. Whether plaintiffs who had no marijuana-related convictions and were not confused by the application were within the class of persons protected by sections 432.7 and 432.8 and could recover statutory damages automatically.
3. Whether writ relief was appropriate from the trial court's order denying Starbucks's motion for summary judgment.

Disposition

writ_granted