Peters v. Guaranteed Rate, Inc.
- Vince Chhabria
- 3:23-cv-05602
- U.S. District Court · Northern District of California
- 2
In Peters v. Guaranteed Rate, Judge Chhabria granted in part conditional certification for California opt-in plaintiffs and required revised notice.
The 35 other opt-in plaintiffs, potential California opt-ins, Robert Peters, and Guaranteed Rate, Inc.
What happened
In Peters v. Guaranteed Rate, Inc., the court considered whether workers could proceed together under the Fair Labor Standards Act and whether the case should be paused during Guaranteed Rate’s appeal concerning arbitration for Robert Peters.
The court ruled that the appeal required a pause only for Peters, not for the 35 other workers who had joined the case. It also limited the certification and notice process to workers who opt in from California because the Ninth Circuit is considering the personal-jurisdiction issue for out-of-state workers.
Judge Vince Chhabria granted the motion for conditional certification in part. He ordered the plaintiffs to submit a revised notice within seven days explaining that workers could be required to arbitrate after opting in.
The detailed version
- Peters v. Guaranteed Rate, Inc. · No. 3:23-cv-05602
- Vince Chhabria
- Aug. 19, 2024
Background
The plaintiffs sought conditional certification of a Fair Labor Standards Act (FLSA) collective action. Conditional certification is an early-stage decision allowing potential members of a group to receive notice and choose whether to join the case. Guaranteed Rate opposed the motion.
Guaranteed Rate argued that the court could not decide the certification motion because its appeal from the denial of its motion to compel Robert Peters to arbitration required the case to be stayed. It relied on Coinbase, Inc. v. Bielski. Guaranteed Rate also argued that notice could not be sent to potential members outside California because the court lacked personal jurisdiction over those plaintiffs, relying on Bristol-Myers Squibb Co. v. Superior Court of California.
Court’s reasoning
The court rejected the argument for a broader stay. It explained that an FLSA collective action differs from a class action because each worker who opts in has party status and is asserting that worker’s own claims. Guaranteed Rate had moved to compel arbitration only as to Peters. Therefore, the appeal and any required stay applied only to Peters. The appeal would not require the 35 other opt-in plaintiffs to stop advancing their cases. Guaranteed Rate could separately move to compel arbitration for additional opt-in plaintiffs who had signed arbitration agreements.
The court limited the certification and notice to California opt-ins because the Ninth Circuit was expected to decide the personal-jurisdiction issue in a pending case. The court stated that the plaintiffs could renew their request for nationwide conditional certification depending on the Ninth Circuit’s decision.
Ruling
Judge Vince Chhabria granted in part the motion for conditional certification. The certification and notice process in this case will apply only to California opt-ins. The plaintiffs must submit a revised proposed notice within seven days, and the notice must explain that a person could be compelled to arbitration after choosing to opt in.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.