Buford v. Medical Solutions, L.L.C.

Background

Laura Buford brought this class action on behalf of herself and others similarly situated against Medical Solutions, L.L.C. The judgment describes the settlement class as California non-exempt employees, including traveling healthcare professionals, who worked an assignment at a facility operated by Sutter Health or a related company during the settlement class period and did not opt out. The judgment also addresses claims under California’s Private Attorneys General Act (PAGA), including civil penalties sought on behalf of the state through the California Labor and Workforce Development Agency (LWDA).

The court considered two unopposed motions heard on July 21, 2020: Buford’s motion for final approval of the class action settlement and her motion for attorney’s fees and costs. The court had entered an order granting both motions on July 28, 2020, and then entered this judgment.

Settlement Approval and Payments

The court found that notice of the settlement was properly mailed to class members, that the notice was the best practicable under the circumstances, and that the LWDA was properly notified of the PAGA claims. No class member or the LWDA objected to the settlement, the requested attorney’s fees and costs, or the representative enhancement payment.

The court found that the settlement resulted from good-faith, arm’s-length negotiations involving experienced counsel and a mediator. After considering the factors identified in the judgment, including Medical Solutions’ potential exposure, the costs and risks of continued litigation, the risk of maintaining class certification through trial, counsel’s experience and views, and the class’s response, the court found the settlement fair, reasonable, adequate, and in the class’s best interests. It granted final approval and ordered the parties to perform the settlement.

The judgment approved these payments:

- $7,500 to Buford as a class representative enhancement payment; - $25,000 to CPT, Inc., the settlement administrator; - $157,500 to the LWDA for its share of PAGA civil penalties; and - $287,500 in attorney’s fees, equal to 25% of the total settlement fund, plus $11,881.82 in litigation costs.

Releases, Opt-Outs, and Judgment

The judgment provided that participating class members, to the extent specified in the settlement agreement, conclusively released the released parties from claims based on the factual allegations in the operative complaint. It also released the relevant PAGA civil-penalty claims alleged in, or that could have been alleged in, the action based on those factual allegations.

Kayla Smith and Janon Ashcraft timely and validly opted out. They were excluded from the class and were not bound by the settlement agreement, the final approval order, or this judgment. The judgment also stated that the releases did not affect claims alleged in a separate action identified as Dittman v. Medical Solutions, L.L.C., et al., Eastern District of California Case No. 2:17-cv-01851-MCE-CKD.

The judgment stated that Buford, on behalf of herself and the state through the LWDA, and the LWDA concerning the specified PAGA claims, would take nothing from Medical Solutions except as provided in the settlement agreement. The court retained jurisdiction for three years from the judgment date to interpret, implement, and enforce the judgment and settlement.

Court’s Stated Limits on the Judgment

The court emphasized that the settlement, final approval order, and judgment were not admissions or concessions of fault, liability, or wrongdoing. The judgment was not a finding that the claims were valid or invalid and did not express the court’s view of the merits of any party’s claims or defenses.