Jimenez v. Haxton Masonry, Inc.

Background

David Jimenez worked for Haxton Masonry, Inc. as a concrete finisher between 2013 and 2017. He brought a class action alleging claims under the federal Fair Labor Standards Act and several California statutes. The state-law claims included alleged failures to pay travel expenses, pay all wages due, pay wages when due, provide accurate itemized wage statements, comply with California’s private-attorney-general statute, and refrain from unfair business practices.

Haxton Masonry’s California projects included work at Camp Pendleton, Point Mugu, Navy Base Coronado, Naval Base Point Loma, Seal Beach, and Miramar. The parties did not dispute that Jimenez and putative class members worked at each site. Haxton Masonry sought partial summary judgment on specified parts of the six California claims based on the federal enclave doctrine.

Evidence and Procedure

Jimenez objected to portions of a declaration from Cassandra Reed, Haxton Masonry’s office manager and former senior project administrator, payroll administrator, and contracts administrator. He argued that the declaration contained hearsay and that Reed lacked personal knowledge. The court overruled both objections, concluding that the evidence could be presented in admissible form at trial and that Reed qualified to provide the foundation for business records. The court also granted Haxton Masonry’s unopposed requests for judicial notice.

Jimenez argued that a partial summary-judgment motion was procedurally deficient. The court rejected that argument, explaining that Rule 56 permits a party to seek summary judgment on a claim or on part of a claim. The court concluded that Haxton Masonry’s motion addressed distinct parts of the claims with sufficient precision.

Federal Enclave Doctrine

The federal enclave doctrine concerns land acquired by the United States over which the federal government has exclusive jurisdiction. The court explained that claims are barred when they arise on a federal enclave and depend on state laws enacted after the enclave was created, unless an exception applies. The court identified three relevant inquiries: whether the site is a federal enclave and when it became one; whether the claim arose from the enclave; and whether the claim existed before the enclave was created.

Haxton Masonry asserted that Camp Pendleton became a federal enclave in 1942, Point Mugu in 1954, Navy Base Coronado in 1921, Naval Base Point Loma in 1852, Seal Beach in 1944, and Miramar in 1943. Jimenez did not dispute those assertions. The court therefore found no genuine dispute of material fact that the six sites were federal enclaves and that they became enclaves on those dates.

The court also found no genuine dispute that the state laws underlying the challenged claims were enacted after the relevant enclave dates, except for the parties’ dispute concerning the second cause of action. The court agreed with Haxton Masonry that Jimenez’s claims for unpaid travel time and wages stemmed from travel to and from the federal-enclave jobsites. It reasoned that the travel was undertaken solely to reach the actual workplaces and was a preliminary or postliminary activity connected to work at those sites. Because the claims stemmed from work performed on federal enclaves, the court held that the federal enclave doctrine barred them.

Unjust-Enrichment Argument

Jimenez argued that his California Labor Code section 2802 travel-expense claim could survive because it was based on common-law unjust enrichment, which he contended predated the creation of the six enclaves. The court rejected that argument. It agreed with Haxton Masonry that Jimenez had not pleaded unjust enrichment as a separate cause of action and that section 2802 did not contain the elements of unjust enrichment identified by the defendant. The court therefore found no genuine dispute of material fact that the second cause of action did not survive the federal enclave doctrine.

Disposition

The court granted Haxton Masonry’s motion for partial summary judgment on these specified claims and locations:

- The second cause of action, under California Labor Code section 2802, for travel expenses arising from work at Navy Base Coronado and Naval Base Point Loma. - The third cause of action, under California Labor Code sections 510, 558, 1194, and 1198, for wages arising from work at Navy Base Coronado and Naval Base Point Loma. - The fourth cause of action, under California Labor Code sections 201–203, for wages allegedly not paid when due arising from work at Navy Base Coronado and Naval Base Point Loma. - The fifth cause of action, under California Labor Code section 226, for itemized statements arising from work at Camp Pendleton, Navy Base Coronado, and Naval Base Point Loma. - The sixth cause of action, under California Labor Code section 2699 and following, under California’s Private Attorneys General Act, arising from work at Camp Pendleton, Navy Base Coronado, Naval Base Point Loma, Miramar, Seal Beach, and Point Mugu. - The seventh cause of action, under California Business and Professions Code section 17200 and following, for unfair business practices arising from work at Camp Pendleton, Navy Base Coronado, Naval Base Point Loma, Miramar, Seal Beach, and Point Mugu.

The court did not state in this order that it resolved Jimenez’s federal claims or every part of the case.