Ebony Byrd v. M.A.C. Cosmetics Inc

Background

M.A.C. Cosmetics, Inc. moved to dismiss Ebony Byrd’s complaint or, alternatively, to stay the action. The opinion refers to a related case, Maciel v. M.A.C. Cosmetics, Inc., involving nearly identical proposed classes, the same defendant, and significantly similar facts and claims. The opinion does not describe the underlying claims in detail.

The court noted that M.A.C. primarily relied on the first-to-file rule. But the court explained that it remained an open question in the Ninth Circuit whether that rule applies to two actions filed in the same district. The court therefore did not resolve that issue.

Reasoning

The court relied instead on its inherent authority to control the cases on its docket. In deciding whether to stay a case, courts weigh the possible harm from a stay, the hardship or unfairness of requiring a party to proceed, and whether a stay would promote the orderly resolution of issues, evidence, and legal questions.

The court found a stay appropriate because the two cases were at substantially different stages. Discovery had closed in Maciel, and briefing on class certification was expected to finish within several months. Discovery had not yet begun in Byrd. The court found no obvious harm from staying Byrd’s case and concluded that a stay would likely simplify the issues and promote efficient use of judicial resources.

Ruling

Judge Araceli Martinez-Olguin granted M.A.C.’s motion for a discretionary stay. The court stayed the action pending further proceedings in Maciel. The opinion does not state that the court granted M.A.C.’s request to dismiss the complaint. The court also vacated the hearing scheduled for October 21, 2024.