Woods v. C.H. Robinson Company, Inc
- Sallie Kim
- 3:25-cv-00294
- U.S. District Court · Northern District of California
- 9
In Woods v. C.H. Robinson Company, Inc., Judge Kim granted remand because Defendant did not prove CAFA’s $5 million amount-in-controversy requirement.
Elizabeth Woods and the proposed class of C.H. Robinson employees, as well as C.H. Robinson Company, Inc.; the case was returned to state court, and the opinion states that the company may attempt removal again if it later obtains supporting evidence.
What happened
Woods v. C.H. Robinson Company, Inc. is a wage-and-hour class action that Defendant removed from California state court under the Class Action Fairness Act. Defendant estimated that more than $8.8 million was at stake, while Plaintiff argued that the estimate relied on unsupported assumptions.
The court found Defendant’s assumptions unreasonable. In particular, Defendant assumed that every class member worked one hour of unpaid overtime per week and that every class member missed qualifying meal and rest breaks, without support from the complaint or other evidence. Without those amounts, Defendant’s estimate was below CAFA’s $5 million threshold.
Judge Kim granted Plaintiff’s motion to remand the case to Contra Costa Superior Court. The court said Defendant could try to remove the case again if it later found evidence showing that the jurisdictional threshold was met.
The detailed version
- Woods v. C.H. Robinson Company, Inc · No. 3:25-cv-00294
- Sallie Kim
- Mar. 26, 2025
Background
Elizabeth Woods, a former employee of C.H. Robinson Company, Inc., filed a proposed class action in Contra Costa Superior Court under California wage-and-hour laws. The complaint asserted claims involving overtime pay, meal periods, rest periods, sick time, business-expense reimbursement, wage statements, and unfair competition. The complaint did not estimate damages.
C.H. Robinson removed the case to federal court under the Class Action Fairness Act, a federal statute that permits federal jurisdiction over certain class actions. The company argued that the amount in controversy was $8,869,192. Its calculation included assumptions that each proposed class member worked one hour of unpaid overtime per workweek, missed one meal break and one rest break per workweek, experienced one wage-statement violation per pay period, and incurred $5 in unreimbursed business expenses per workweek.
Woods moved to remand, meaning she asked the federal court to send the case back to state court. She challenged the assumptions supporting the amount-in-controversy calculation. She did not challenge the company’s valuation of the business-expense claim.
Legal Standard
The parties did not dispute CAFA’s requirements concerning the minimum diversity of citizenship or the number of proposed class members. The only dispute was whether the amount in controversy exceeded $5 million.
Because the complaint did not specify damages, C.H. Robinson had to support its jurisdictional allegation with proof after Woods made a factual challenge. The court explained that the company had the burden of proving, by a preponderance of the evidence, that its assumptions were reasonable and that the amount in controversy exceeded $5 million. Woods did not need to submit outside evidence or provide an alternative calculation; she could challenge removal by showing through argument that the company’s assumptions were unsupported.
Court’s Analysis
Overtime claim. Woods alleged that C.H. Robinson underpaid overtime because it failed to include forms of compensation such as shift pay, bonuses, commissions, stipends, and incentives when calculating the regular rate used for overtime. She did not allege that class members received no overtime pay for particular overtime hours.
The court therefore found unreasonable C.H. Robinson’s assumption that each class member worked one entirely unpaid overtime hour per workweek. The assumption valued a different type of claim from the one alleged. Because the parties provided no information about the range of additional compensation that would affect the proper overtime rate, the court could not calculate a better alternative and assigned the overtime claim a value of $0 for the amount-in-controversy analysis.
Meal and rest period claims. C.H. Robinson assumed that each proposed class member missed one meal period and one rest period per workweek. The company offered no evidence that all class members worked shifts long enough to qualify for those breaks. The complaint stated that class members worked various shifts, many of which lasted more than eight hours in a workday, but it did not allege that every class member worked qualifying shifts.
The court found the assumption unsupported by both the complaint and the other evidence. It also found that neither party submitted information about the length of class members’ workdays that would allow the court to calculate a different amount.
Wage-statement and expense claims. C.H. Robinson estimated $2,550,500 for the wage-statement claim and $296,945 for the business-expense claim, for a combined total of $2,847,445. Because this total was below $5 million even before considering whether the wage-statement estimate was supported, the court did not decide whether that estimate was proven by a preponderance of the evidence.
Disposition
The court held that C.H. Robinson had not carried its burden of proving that CAFA’s amount-in-controversy requirement was satisfied. Judge Sallie Kim granted Woods’s motion to remand and sent the case back to Contra Costa Superior Court. The court stated that C.H. Robinson could attempt to remove the case again if it later discovered evidence showing that the jurisdictional threshold was met.
Read the full 9-page opinion on CourtListener, the free public archive maintained by the Free Law Project.