Diaz v. Amazon.com, Inc.
- Vince Chhabria
- 3:20-cv-07792
- U.S. District Court · Northern District of California
- 5
In Diaz v. Amazon.com, Inc., Judge Chhabria transferred the case to Washington under the first-to-file rule with the parties’ agreement.
Ricky Diaz, Emanuel Adamson, and Juan Manuel Alvarez; Amazon.com, Inc. and Amazon Logistics, Inc.; and members of the proposed class of California-based Amazon Delivery Partners.
What happened
In Diaz v. Amazon.com, Inc., three plaintiffs sued Amazon under California labor law on behalf of a proposed class of delivery partners. They alleged that Amazon wrongly classified those workers as independent contractors.
The parties agreed that earlier related class actions involved the same defendants, overlapping issues, and proposed classes that included these plaintiffs. They therefore asked the court to transfer this case to the Western District of Washington under the first-to-file rule.
Judge Vince Chhabria ordered the transfer, vacated all existing deadlines, and left future deadlines to the Washington court. The order also stated that Amazon could still file a motion, including a motion to compel arbitration, or another response to the complaint.
The detailed version
- Diaz v. Amazon.com, Inc. · No. 3:20-cv-07792
- Vince Chhabria
- Mar. 23, 2021
Background
Ricky Diaz, Emanuel Adamson, and Juan Manuel Alvarez brought the case individually and on behalf of a proposed class. They alleged various violations of the California Labor Code based on the theory that Amazon Delivery Partners were misclassified as independent contractors. The defendants were Amazon.com, Inc. and Amazon Logistics, Inc., along with unnamed defendants.
The plaintiffs originally filed the complaint in Alameda County Superior Court on August 21, 2020. Amazon removed the action to the Northern District of California on November 4, 2020. The parties later agreed to stay the case while the United States Supreme Court considered a petition seeking review of an earlier related decision. The Supreme Court denied that petition on February 22, 2021.
Transfer Request
At a March 10, 2021 case-management conference, Amazon stated that it intended to seek arbitration or dismissal, a stay, or transfer under the first-to-file rule. The court indicated that it was inclined to transfer the action to the Western District of Washington and asked the parties to discuss a stipulation.
The parties agreed that this action and earlier related cases had enough similarity to justify applying the first-to-file rule. They stated that the plaintiffs were members of the proposed classes in those earlier cases, that the defendants were the same, and that the issues substantially overlapped, including the theory that Amazon Delivery Partners were misclassified as independent contractors.
Ruling
The court approved the parties’ stipulation and ordered that the matter be transferred to the Western District of Washington. It vacated all deadlines and directed that any new deadlines be set by the Washington court. The court also specified that the transfer order did not limit or affect Amazon’s ability to file a motion, including a motion to compel arbitration, or another responsive pleading to the complaint.
The order addressed the case’s forum and scheduling; it did not decide whether the plaintiffs’ labor-law allegations were valid or whether Amazon could compel arbitration.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.