Judge Jennifer Thurston, who was nominated by President Biden to the Eastern District of California, rejected a motion by a large California citrus grower for summary judgment in a class action lawsuit by workers charging the company with wage and other labor violations. The case can now continue to a trial on the merits of the workers’ complaints The October 2024 decision was in Marquez v Bee Sweet Citrus Inc.
What happened in this case?
Bee Sweet Citrus Inc. is a large commercial fruit grower in California. It “hires thousands of seasonal agricultural workers” before and during harvesting season. Rafael Marquez Amaro and Javier Berrera are farmworkers hired by Bee Sweet. They filed a class action lawsuit contending that the corporation failed to pay employees for all hours worked, failed to provide proper breaks, and committed other violations of federal and state law. For example, the complaint contends that the company required workers to report at specified times and then told to “wait up to four hour before they could begin harvesting. ” They were also required to “use their own vehicles to travel between fields in the middle of their shifts. ” However but the corporation failed to pay workers “for the time and expense.”
After some discovery, Bee Sweet filed a motion for summary judgment to dismiss the case before it could get to a jury for trial. The company asserted the case should be thrown out for three reasons: 1/ the plaintiffs’ “failure to join independent labor contractors and neighboring farmers” in the suit; 2/ “various deficiencies” in the complaint’s private attorney general claims; and 3/ plaintiffs’ alleged “failure to give proper notice” under the California labor code.
How did Judge Thurston decide the case and why is it important?
Judge Thurston issued a comprehensive opinion that rejected all three of the corporation’s arguments. Accordingly, she turned down Bee Sweet’s efforts to throw out the case, which will now continue.
Initially, Bee Sweet asserted that the farmworkers must include in the case neighboring farmers and independent labor contractors who also hired some of the farmworkers, or the case must be dismissed. Judge Thurston disagreed. She pointed out that the plaintiffs had alleged violations only against Bee Sweet, “not any other” employers. Accordingly, she ruled that both state statutes and applicable precedent make clear that joinder Is not required, and the corporation’s contrary argument is “patently meritless.”
In addition, Judge Thurston rejected the corporation’s arguments against the farmworkers’ claims under California’s private attorney general law, which allows private parties to recover civil penalties for violation of state labor code provisions. Contrary to Bee Sweet’s claims, she explained, recovery under the private attorney general act is not the same as payment of wages that are due. Instead, she wrote, such recovery “is intended to penalize the employer for the failure to comply” with the state labor code. The farmworkers can legally pursue both, and she thus denied the corporations’ arguments against going forward with the private attorney general act claims.
Judge Thurston also rejected the corporation’s assertion that the plaintiffs did not provide proper notice of their claims under California state law. She carefully considered the facts and concluded that the plaintiffs had “properly pled compliance with the notice requirements” of the law.
Judge Thurston’s opinion is obviously important to Rafael Marquez Amaro, Javier Berrera, and the other farmworkers who can now proceed to get compensation and justice from the Bee Sweet corporation. The decision also provides useful guidance on interpreting California law concerning labor law violations, especially in the Ninth Circuit, which includes California, Washington, Arizona, Alaska, Hawaii, Idaho, Montana, Nevada and Oregon. In addition, the decision serves as a reminder of the importance of promptly confirming fair-minded judges to our federal courts.