Webb v. Rejoice Delivers LLC

Background

Ian Webb alleged that he worked for about four weeks as a delivery driver employed by Rejoice Delivers LLC. Rejoice issued his paystubs, set his work schedule, and dispatched him to Amazon warehouses. Webb alleged that Amazon Logistics, Inc. and Amazon.com Services, LLC jointly employed him with Rejoice.

Webb alleged that he worked through meal and rest breaks, was not paid for that work, and worked more than eight hours per day or 40 hours per week without overtime pay. He asserted seven California wage-and-hour claims: unpaid overtime, failure to provide meal periods, failure to provide rest periods, unpaid minimum wages, waiting-time penalties, inaccurate wage statements, and failure to reimburse business expenses. He also proposed a class covering all hourly-paid, non-exempt Rejoice employees in California whom he alleged were jointly employed by the Amazon entities.

Legal standard

The defendants moved to dismiss 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 facts to make the claim plausible. The court generally treated the factual allegations as true for purposes of the motion. It also considered whether Webb had plausibly alleged class allegations, although class-certification requirements are generally addressed later in a case.

Joint-employer allegations

The court held that Webb did not allege enough facts to show that Amazon Logistics or Amazon.com controlled his wages, hours, or working conditions as required for joint-employer liability under California law. The complaint often referred to the defendants collectively and did not distinguish between the two Amazon entities. The court found that the allegations about Amazon-branded uniforms and vans, the Amazon Flex app, delivery routes, and package quotas did not adequately establish the required control, and that the lack of differentiation between the Amazon entities was independently insufficient.

The motion to dismiss was granted as to all claims against Amazon Logistics and Amazon.com, without leave to amend.

Claims against Rejoice

The court found that Webb’s basic overtime allegations were sufficient to proceed because he alleged that he worked more than eight hours per day or 40 hours per week and was not paid overtime. The court noted that whether he actually worked those hours was a factual question for a later stage. However, the court dismissed Claim 1 to the extent it relied on Rejoice’s alleged failure to include non-discretionary bonuses, incentives, and shift differentials in overtime calculations, without leave to amend.

The court also found that Webb adequately alleged a minimum-wage claim based on work performed while he was clocked out during meal periods. His allegations that package quotas made it effectively impossible to complete deliveries while taking breaks, and that dispatch called when drivers stopped, were sufficient at the pleading stage. The court dismissed Claim 4 to the extent it relied on the alleged failure to include non-discretionary bonuses, incentives, and shift differentials when calculating paid sick leave, without leave to amend.

The court allowed Claims 2 and 3, concerning meal and rest periods, to proceed. It also allowed Claim 5 for waiting-time penalties and Claim 6 for inaccurate wage statements to proceed because those claims were derivative of the overtime and minimum-wage claims that survived. The court dismissed Claim 7 for failure to reimburse business expenses because Webb did not identify a specific instance when he incurred cellphone expenses and Rejoice failed to reimburse him. That dismissal was without leave to amend.

Class allegations

The court dismissed the class allegations because the proposed class included all hourly-paid, non-exempt Rejoice employees, not just delivery drivers. Webb had not alleged that employees in other positions experienced the same meal-and-rest-break or wage-and-hour violations. The court granted leave to amend the class allegations so that Webb could limit the proposed class to Rejoice delivery drivers dispatched to provide services for Amazon Logistics and Amazon.com.

Disposition

The motion to dismiss the fourth amended complaint was GRANTED IN PART AND DENIED IN PART, WITH LEAVE TO AMEND IN PART AND WITHOUT LEAVE TO AMEND IN PART. It was granted in part without leave to amend as to all claims against Amazon Logistics and Amazon.com, the specified portions of Claims 1 and 4, and Claim 7. It was granted in part with leave to amend as to Webb’s class allegations. It was denied as to Claims 1 through 6 against Rejoice, except for the specified portions of Claims 1 and 4.

Judge Beth Labson Freeman ordered Webb to file a fifth amended complaint by August 21, 2025. The amendment was limited to the class allegations, and Webb could not add new claims or parties without the court’s express permission.