Mabanta v. Prime Now LLC

Background

Mario Mabanta sued Prime Now LLC and Amazon.com, Inc. He alleged that the defendants violated several California Labor Code provisions and California’s unfair-competition law in their treatment of him and other workers who fulfilled delivery orders. The case was filed as an individual and proposed class action in California state court and was later transferred to federal court.

The complaint asserted claims for unpaid wages; failure to reimburse necessary business expenses; failure to pay minimum wages; failure to provide rest periods; failure to pay for reporting time; inaccurate wage statements; waiting-time penalties; and unlawful and unfair business practices.

According to the allegations summarized by the court, workers using the defendants’ mobile application shopped for, purchased, and sometimes delivered groceries and other goods. Workers hired under a “Regular Adjustable Hours” agreement had to log on and select available shifts. Mabanta alleged that workers were required to spend uncompensated time waiting to select shifts and risked discipline or termination if they did not sign up for enough shifts. He also alleged that the defendants did not reimburse expenses such as remote internet or cell-phone data access and did not provide required rest breaks during shifts.

Arguments and analysis

The defendants argued that the complaint described employees’ experiences generally and lacked facts about Mabanta’s personal experience. They also argued that the complaint did not say whether Mabanta still worked for them.

The court applied the pleading standard requiring factual allegations that plausibly support a legal claim. It concluded that the complaint alleged enough facts to suggest that the defendants had created a system requiring California employees to perform work without compensation. Although the complaint sometimes referred to Mabanta and proposed class members collectively, it also included specific facts supporting the different Labor Code claims.

The court held that Mabanta did not need to provide a detailed list of expenses to state the reimbursement claim. It also held that he did not need to identify the exact dates or hours of each alleged wage violation at this stage. For the rest-break claim, the court found sufficient Mabanta’s allegation that associates regularly worked more than four hours per shift without being allowed an uninterrupted rest break.

Ruling

The court denied the motion to dismiss. It found that Mabanta had sufficiently alleged that he and the proposed class were not paid for time or expenses connected with signing up for shifts and were not provided adequate rest breaks or compensation for missed breaks. The court did not decide whether those allegations were ultimately proven. The defendants were ordered to file an answer within 21 days, and the initial case-management conference was to proceed on August 10, 2020. The order terminated Docket No. 11.