Franklin v. Home Depot U.S.A., Inc.

Background

Travis Franklin sued his former employer, Home Depot U.S.A., Inc., in a proposed class action. He alleged violations involving minimum wages, overtime, meal and rest periods, wage statements, business-expense reimbursement, final wages, and paid sick leave. He also asserted a claim under California’s unfair-competition law. The case was filed in California state court and later removed to federal district court.

The complaint asserted nine claims: unfair competition and eight California Labor Code claims. The proposed classes included non-exempt people who were or had been employed by Home Depot in California, including people staffed through a third party. The complaint also alleged that Franklin and other class members underwent temperature checks and symptom questions before clocking into the timekeeping system.

Motions and analysis

Home Depot moved to dismiss all claims under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not state a legally sufficient claim supported by enough factual detail. Home Depot also moved to dismiss the class allegations or, alternatively, to strike them under Rule 12(f).

The court held that Claims 2–9 were based on conclusory, boilerplate allegations. The complaint did not include facts specific to Home Depot’s conduct or Franklin’s experience. For example, it did not explain whether or how an alleged rest-period policy affected Franklin, or identify a specific workweek in which he allegedly worked without proper overtime pay.

The court also dismissed Claim 1 because it depended on the inadequately pleaded Labor Code violations. In addition, the court held that Franklin lacked standing to seek injunctive relief because the complaint stated that he was no longer employed by Home Depot. The court found that the proposed class allegations lacked facts supporting a plausible inference that the class members experienced Labor Code violations.

Disposition

The court granted the motion to dismiss the complaint as to all claims, with leave to amend in part and without leave to amend in part. Leave to amend was granted for Claims 2–9 and for Claim 1 to the extent it sought restitution. Leave to amend was denied for Claim 1 to the extent it sought injunctive relief.

The court granted the motion to dismiss the class allegations with leave to amend. It denied as moot Home Depot’s alternative motion to strike the class allegations.

Judge Beth Labson Freeman ordered Franklin to file an amended complaint within 30 days after the order, by October 20, 2025. The order states that Franklin could not add new claims or parties without express permission from the court.