Ramirez v. Anvil Builders, Inc.

Background

Fernando Ramirez alleged that Anvil Builders, Inc. failed to pay him for compensable work performed outside his scheduled work time, including travel in a company truck and loading and unloading equipment. He also alleged that Anvil failed to provide timely, compliant meal and rest periods. Ramirez asserted claims under the California Labor Code and California Unfair Competition Law (UCL).

Anvil removed the case from Alameda County Superior Court to federal court, arguing that the Labor Management Relations Act (LMRA) preempted some claims because Ramirez was covered by a collective bargaining agreement (CBA). Anvil then petitioned to compel arbitration of several remaining claims and moved for partial summary judgment on Ramirez’s overtime, meal-period, rest-period, and related UCL claims.

Federal jurisdiction and labor-law preemption

The court found that Anvil was a signatory to the 2018–2023 Laborers Master Agreement and that the agreement covered Ramirez. Applying the Ninth Circuit’s two-step test for LMRA preemption, the court held that Ramirez’s California Labor Code Section 510 overtime claim was preempted because the CBA satisfied California Labor Code Section 514. The CBA addressed wages, hours, and working conditions, provided premium overtime rates, and set a regular hourly wage above the required threshold. The court therefore held that federal jurisdiction existed over the overtime claim and that it could have supplemental jurisdiction over related state-law claims.

Partial summary judgment

The court granted Anvil’s motion for partial summary judgment. It held that the CBA exempted Ramirez from California’s overtime requirements because it met Section 514’s conditions. The court rejected Ramirez’s argument that the CBA did not cover “off the clock” travel time or did not provide premium pay for every overtime hour. The court reasoned that the CBA’s provisions covering work before and after a shift included compensable off-the-clock work if such work was established.

The court also held that the CBA exempted Ramirez from the applicable meal-period requirements because Ramirez worked in construction, the CBA provided for meal periods and final and binding arbitration of meal-period disputes, and the agreement met the other statutory requirements. It further held that the CBA provided protections equivalent to those required by the applicable rest-period wage order. The portion of Ramirez’s UCL claim derived from the overtime, meal-period, and rest-period claims also failed as a matter of law.

Arbitration petition and remand

After granting summary judgment on the claims over which it had original jurisdiction, the court declined to exercise supplemental jurisdiction over Ramirez’s remaining state-law claims. It concluded that the state court was the more appropriate forum to address whether those claims were subject to arbitration. The court remanded the case to Alameda County Superior Court and directed the clerk to terminate Anvil’s petition to compel arbitration without prejudice and close the federal case.

Disposition

The court granted Anvil’s motion for partial summary judgment as to Ramirez’s overtime, meal-period, and rest-period claims and the related portion of his UCL claim. It remanded the case to Alameda County Superior Court and terminated the arbitration petition without prejudice.