Turner v. Alclear, LLC

Summary

The United States District Court for the Eastern District of California denied Plaintiff Tyonna Turner’s motion to remand a wage-and-hour class action removed under the Class Action Fairness Act. The court held that Defendant established by a preponderance of the evidence that the waiting-time-penalties claim alone placed more than $5 million in controversy.

Holdings

1. Defendant established by a preponderance of the evidence that the amount in controversy exceeded $5 million because its waiting-time-penalty calculation alone totaled $5,100,480.
2. Separate calculations for overtime, sick pay, meal and rest periods, and reimbursement claims were unnecessary because the waiting-time-penalty claim alone placed more than $5 million in controversy.
3. The court did not need to decide whether attorneys' fees could be calculated from the waiting-time-penalty claim because the amount in controversy exceeded $5 million without including attorneys' fees.

Questions Presented

1. Whether Defendant established by a preponderance of the evidence that the amount in controversy exceeded $5 million for CAFA jurisdiction.
2. Whether Defendant's evidence and assumptions supported an amount-in-controversy calculation based on maximum waiting-time penalties for the putative class.
3. Whether the absence of separate calculations for certain wage claims and attorneys' fees required remand.

Disposition

other