Webb v. Rejoice Delivers LLC

Background

Ian Webb brought a proposed class action against his former employer, Rejoice Delivers LLC, and against Amazon Logistics, Inc. and Amazon.com Services, LLC. Webb alleged that Rejoice and Amazon were joint employers and asserted nine claims under California wage-and-hour laws and California’s Unfair Competition Law:

The defendants moved to dismiss the third amended complaint under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not state a legally recognized claim supported by enough factual allegations. They also moved to dismiss the class allegations under Rule 12(b)(6) or, alternatively, to strike them under Rule 12(f).

Reasons for the Ruling

The court found that the third amended complaint relied on conclusory, boilerplate statements. It did not identify Webb’s job or the jobs of the proposed class members, distinguish between Rejoice’s and Amazon’s alleged conduct, or explain facts showing how each defendant was an employer or committed a particular violation.

The court separately found that Claims 1–8 lacked facts supporting the alleged Labor Code violations. For example, the complaint alleged that the defendants failed to reimburse business expenses but did not identify the expenses, explain why they were reimbursable, or describe how reimbursement was refused.

The court dismissed Claim 8 under Labor Code § 229. The defendants argued that the statute does not create a private right to sue and that Webb’s claim duplicated his other Labor Code claims. Because Webb did not address those arguments in his opposition, the court treated them as conceded. The court also stated that the claim was subject to dismissal because it was derivative of and duplicative of the other Labor Code claims.

The court dismissed Claim 9 under the Unfair Competition Law. Because that claim was based on the same wage-and-hour violations alleged in Claims 1–8, the court found that Webb could not allege that his legal remedies were inadequate, a requirement for the equitable restitution he sought. The court also stated that Webb lacked standing to seek injunctive relief because he was no longer employed by the defendants.

The court dismissed the class allegations under Rule 12(b)(6), finding that the complaint contained no facts about a policy or procedure supporting a plausible inference that all California non-exempt employees of Rejoice and Amazon experienced Labor Code violations. Because the class allegations were dismissed under Rule 12(b)(6), the court denied the defendants’ alternative motion to strike them under Rule 12(f) as moot.

Leave to Amend and Order

The court concluded that amendment would not be futile for Claims 1–7 because Webb’s counsel represented that additional facts could be alleged. Counsel also represented that the class allegations could be amended. The court found amendment futile for Claims 8–9: it stated that a private right of action did not appear to exist under § 229 and that Claim 8 was duplicative, while Claim 9 could not be amended to allege inadequate legal remedies for the underlying Labor Code violations.

Judge Beth Labson Freeman ordered that the motion to dismiss the third amended complaint be granted as to all claims and class allegations, with leave to amend in part and without leave to amend in part. Leave to amend was granted for Claims 1–7 and the class allegations, and denied for Claims 8 and 9. Webb was required to file a fourth amended complaint within 14 days of the order, by April 15, 2025, limited to deficiencies in Claims 1–7 and the class allegations. He could not add new claims or parties without express court permission.

The court extended the discovery stay through the filing of the fourth amended complaint, at which time the stay would be lifted without further action. The order terminated ECF 124.