Meadows v. American Addiction Centers, Inc.

Background

Willie R. Meadows filed this putative class action against American Addiction Centers, Inc. (AAC), his former employer. The lawsuit asserts claims under federal and state credit-reporting laws, state wage-and-hour laws, state unfair-competition law, and California’s Private Attorneys General Act. AAC removed the case from state court to federal district court, and Meadows later filed an amended complaint adding the Private Attorneys General Act claim.

Caroline Park separately filed a putative class action against AAC in state court. Her proposed amended complaint alleges that she worked for AAC as a non-exempt, hourly nurse from approximately March 2016 through February 22, 2019. She seeks to assert California wage-and-hour claims on behalf of a proposed class of non-exempt, hourly nurses employed by AAC in California, along with a Private Attorneys General Act claim for penalties. The state-court action was stayed.

Intervention analysis

Park sought intervention as of right under Federal Rule of Civil Procedure 24(a). Intervention allows a person who meets specified requirements to join an existing lawsuit. The court explained that Park had to show four things: a significant protectable interest related to the case, a risk that the case could impair her ability to protect that interest, a timely application, and inadequate representation by the existing parties.

The court found that Park satisfied all four requirements. It stated that she appeared to be a member of the proposed class, that the current case could resolve her claims against AAC unless she opted out, and that her application was timely because the case was still in its early stages. The court also found that Meadows might not adequately represent her interests because he had not asserted claims specifically involving nurses who worked an alternative workweek schedule or a separate claim for unpaid overtime—claims Park sought to assert.

Park’s proposed complaint was not attached to her motion as apparently intended. The court nevertheless accepted the description of that complaint in the motion because the motion was signed by Park’s counsel. AAC filed a statement of non-opposition, and Meadows did not respond.

Ruling and required actions

The court vacated the April 16, 2020 hearing on the motion to intervene and granted the Motion to Intervene. It ordered Park to file her Complaint in Intervention separately on or before April 15, 2020. It also ordered Meadows and Park to file a joint status report by April 22, 2020, stating whether they intended to file a consolidated class-action complaint and proposing a schedule for that filing.