Chavez v. Converse, Inc.
- Nathanael Cousins
- 5:15-cv-03746
- U.S. District Court · Northern District of California
- 5
In Chavez v. Converse, Judge Cousins granted Converse summary judgment in part on penalties and post-November 19, 2019 claims, but otherwise denied it.
Chavez, the represented class of employees, and Converse, Inc.; the ruling removed penalties under California Labor Code sections 203 and 226 and claims arising after November 19, 2019, while leaving other claims unresolved.
What happened
Chavez v. Converse, Inc. is a class action about whether Converse owed employees wages for time spent undergoing mandatory exit security inspections. Converse argued that it reasonably believed California law allowed its policy and that the inspections took too little time to require payment.
The court ruled that Converse had a good-faith dispute about whether wages were owed, so it granted summary judgment on penalties under California Labor Code sections 203 and 226. But factual disputes remained about how long the inspections took, whether they were regular, and whether tracking the time was reasonable. The court also denied summary judgment on meal- and rest-break claims and granted summary judgment on all claims after Converse stopped requiring exit inspections on November 19, 2019.
Judge Nathanael M. Cousins granted Converse’s motion for summary judgment in part and denied it in part.
The detailed version
- Chavez v. Converse, Inc. · No. 5:15-cv-03746
- Nathanael Cousins
- Mar. 13, 2020
Background
Eric Chavez represented a class of employees claiming that Converse, Inc. owed wages for time spent undergoing mandatory security inspections. Converse moved for summary judgment, arguing that it adopted the policy based on a good-faith understanding of California law and that the inspection time was de minimis—that is, so small that compensation was not required.
Good-Faith Dispute and Penalties
The court held that California’s good-faith defense applies to wage-statement claims under California Labor Code section 226. A good-faith dispute exists when an employer presents a supported legal or factual defense that, if successful, would prevent the employee from recovering wages. The court concluded that Converse reasonably asserted its de minimis defense because courts and California labor authorities had previously applied a federal de minimis standard to small amounts of time. The law remained uncertain even after the California Supreme Court’s decision in Troester v. Starbucks Corp.
Because Converse had a good-faith dispute, the court granted summary judgment as to penalties under California Labor Code sections 203 and 226. The court explained that Converse did not need to ultimately win its de minimis defense to establish a good-faith dispute.
De Minimis Defense
The court denied summary judgment on the underlying de minimis issue. The record contained a factual dispute about how long the exit inspections took and how regularly they occurred. The court also held that it could not decide on summary judgment whether it was reasonable for Converse to use technological advances to track small amounts of time. It declined to weigh the competing experts’ opinions because credibility and conflicting evidence must be evaluated at trial.
Meal and Rest Breaks
The court denied summary judgment on Chavez’s meal- and rest-break claims. Converse raised an argument about those claims for the first time in its reply, and Chavez had not had an opportunity to respond to it. Neither party raised the issue at the hearing.
Claims After November 19, 2019
Converse undisputedly changed its policies on November 19, 2019, so that exit inspections were no longer mandatory. Chavez conceded that the class had no claims after that date. The court therefore granted summary judgment on all claims after November 19, 2019.
Disposition
The court granted in part Converse’s motion for summary judgment as to penalties under California Labor Code sections 203 and 226. It otherwise denied the motion.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.