Corbin v. Life Care Centers of America, Inc.

Summary

The Washington Court of Appeals, Division One, held that the preclusive effect of a class action settlement is determined by the settling parties’ intent. Because the prior settlement released absent class members’ claims for unpaid COVID-19 testing and screening time, but did not release claims for uncompensated missed meal periods, the court reversed dismissal of Corbin’s putative class action and remanded.

Holdings

1. The settling parties' intent determines the preclusive effect of a class action settlement agreement rather than general claim-preclusion principles applied without regard to the settlement's scope.
2. The Atkinson settlement released absent class members only from claims for unpaid wages due to COVID-19 testing and screening; it did not release or preclude claims for allegedly uncompensated missed meal periods.
3. Dismissal under CR 12(b)(6) was improper because Corbin's complaint was not barred by claim preclusion on the face of the pleadings and settlement materials considered by the court.

Questions Presented

1. Whether the preclusive effect of a court-approved class action settlement is determined by the settling parties' intent and the scope of the settlement release.
2. Whether the Atkinson class settlement released or otherwise precluded Corbin's claims for uncompensated missed meal periods.
3. Whether dismissal under CR 12(b)(6) was proper.

Disposition

reversed_and_remanded