Meek v. Skywest, Inc.

Background

Cody Meek, a former ramp agent at San Francisco International Airport, brought a proposed class action against SkyWest, Inc. and SkyWest Airlines, Inc. He alleged that SkyWest paid employees according to scheduled time rather than time actually worked. His claims included California minimum-wage violations, missed or shortened meal breaks, overtime, inaccurate wage statements, unfair competition, waiting-time penalties, and minimum-wage violations based on San Francisco rules.

The court had previously determined that Meek and SkyWest were parties to a collective bargaining agreement governed by the Railway Labor Act. In this order, the court addressed SkyWest’s motion to dismiss the amended complaint and Meek’s motion asking the court to clarify the scope of an earlier partial summary-judgment ruling.

Minimum-Wage and Meal-Break Claims

SkyWest argued that the Railway Labor Act preempted, or displaced, Meek’s first two claims. The court rejected that argument. Applying the Ninth Circuit’s rule in Alaska Airlines Inc. v. Schurke, the court explained that preemption applies when a claim depends on a right created only by the collective bargaining agreement or when resolving the claim requires interpreting the agreement in a way that threatens the labor agreement’s grievance-and-arbitration process.

The court concluded that Meek’s claims were based on state-law rights, not rights created only by the collective bargaining agreement. It also concluded that SkyWest had shown, at most, that the court might need to refer to or apply the agreement, not interpret it. The court therefore denied SkyWest’s Railway Labor Act preemption arguments.

SkyWest also argued that Meek’s first claim failed because he did not allege that he reported the uncompensated work and sought approval for payment. The court disagreed, pointing to allegations that Meek worked uncompensated time, including early check-ins, missed meal breaks, and work beyond scheduled hours, and that additional work was often not approved for payment. The court found these allegations sufficiently detailed and plausible to proceed under the federal pleading standard.

Overtime Claim and Clarification

The court had previously granted summary judgment to SkyWest on Meek’s third claim for overtime based on an exemption in California Industrial Welfare Commission Wage Order 9. Meek asked whether that ruling also eliminated overtime claims brought under the California Labor Code.

The court clarified that the earlier summary-judgment ruling was limited to overtime wages claimed under Wage Order 9. The court concluded that the exemption’s language did not address employer obligations or employee rights under the California Labor Code provisions Meek invoked. SkyWest had not provided a sufficient reason to prevent Meek from pursuing those Labor Code overtime claims.

Derivative Claims

Meek’s fourth, fifth, and sixth claims concerned inaccurate wage statements, unfair competition, and waiting-time penalties. The court treated these claims as derivative of his other wage claims and denied dismissal to the extent SkyWest argued that the underlying claims were deficient.

Meek stated that he sought actual damages, not statutory penalties, for inaccurate wage statements. Based on that clarification, the court dismissed any claim for statutory penalties based on inaccurate wage statements. The court did not dismiss the claim for actual damages at this stage and stated that it would not allow an unlawful double recovery if the case ultimately proceeded.

San Francisco Minimum-Compensation Claim

Meek’s seventh claim alleged that SkyWest failed to pay the minimum compensation required by San Francisco rules. SkyWest raised several arguments, including Railway Labor Act preemption, failure to exhaust administrative remedies, waiver through a collective bargaining agreement, and the absence of a private right to sue under the airport’s Quality Standards Program.

The court deferred these issues rather than resolving them on the motion to dismiss. It explained that the questions were novel, complex, and dependent on a more developed factual and legal record. The court also noted that Meek’s claim was brought under California Labor Code section 1197, rather than directly under the San Francisco ordinance or Quality Standards Program. Because SkyWest did not dispute Meek’s ability to sue under section 1197, the court found that some of SkyWest’s arguments were not relevant to the claim as pleaded.

Disposition

The court granted SkyWest’s motion to dismiss in part and denied it in all other respects. Specifically, it dismissed any claim for statutory penalties based on inaccurate wage statements, while allowing the remaining challenged claims to proceed or deferring the issues identified above. The court clarified that the previous summary judgment on the overtime claim applied only to Wage Order 9.

The court referred the case to Magistrate Judge Thomas S. Hixson for a settlement conference, following the retirement of Magistrate Judge Elizabeth D. Laporte, and set a further case-management conference for January 16, 2020. The provided signature does not clearly identify the district judge.