Hasty v. Hyatt Corporation
- Lin
- 3:25-cv-04516
- U.S. District Court · Northern District of California
- 2
In Hasty v. Hyatt, Judge Lin denied remand because federal jurisdiction existed under federal labor law and supplemental jurisdiction.
Bradley J. Hasty and Hyatt Corporation; the case remains in federal court and is to be consolidated with Hasty’s related class action.
What happened
Bradley J. Hasty sued Hyatt Corporation in state court under California’s Private Attorneys General Act, seeking civil penalties. Hyatt moved the case to federal court, arguing that federal labor law replaced or controlled Hasty’s claims. Hasty asked the federal court to send the case back to state court.
The court held that it had federal jurisdiction because Hasty’s claim under California Labor Code section 204 was governed by section 301 of the Labor Management Relations Act. Hasty did not dispute that his collective bargaining agreement provided different pay arrangements from section 204(a), and the court said his section 204 claim therefore remained governed by federal law. The court also found supplemental jurisdiction over Hasty’s other claims because they arose from the same working conditions and employment relationship.
Judge Rita F. Lin denied Hasty’s motion to remand. The court ordered this case consolidated with Hasty’s related class action, Hasty v. Hyatt Corp., No. 25-cv-02662-RFL.
The detailed version
- Hasty v. Hyatt Corporation · No. 3:25-cv-04516
- Lin
- Dec. 8, 2025
Background
Bradley J. Hasty filed this action against Hyatt Corporation in state court under California’s Labor Code Private Attorneys General Act (PAGA), seeking civil penalties. Hasty also filed a proposed class action against Hyatt in a separate federal case, No. 25-cv-02662-RFL. Hyatt removed this PAGA action to federal court on the ground that section 301 of the Labor Management Relations Act (LMRA) preempted Hasty’s claims. In the related class action, Hyatt sought consolidation of the two cases. Hasty moved to remand this case to state court.
Court’s Analysis
The court held that it had subject-matter jurisdiction under LMRA section 301 and supplemental jurisdiction under 28 U.S.C. § 1367. Hasty’s complaint alleged that Hyatt violated California Labor Code section 204(a) by failing to pay wages within the statutory time periods. But section 204(c) provides that different pay arrangements in a collective bargaining agreement apply to covered employees. Hasty did not dispute that the collective bargaining agreement governing his employment provided different pay arrangements from section 204(a), including semi-monthly, weekly, or daily payments for some employees.
Hasty stated that he agreed to dismiss his section 204 claim, but he had not actually dismissed it. The court therefore treated the claim as still pending and held that LMRA section 301 preempted it. Because the remaining claims arose from the same working conditions and employment relationship during the same period, the court also held that it had supplemental jurisdiction over those claims.
Disposition
The court denied Hasty’s motion to remand. It ordered that this case be consolidated with Hasty v. Hyatt Corp., No. 25-cv-02662-RFL. The order was entered by United States District Judge Rita F. Lin on December 8, 2025.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.