Jocelyn Trigueros v. Stanford Federal Credit Union

Background

Jocelyn Trigueros brought a proposed class action against her former employer, Stanford Federal Credit Union, alleging violations of California wage-and-hour laws. The proposed class included current and former hourly-paid or non-exempt employees of the credit union in California during the specified class period. The complaint alleged, among other things, failure to pay required wages, provide meal and rest periods, pay related premiums and penalties, pay wages due at discharge, and provide accurate wage statements.

The credit union removed the case from state court under the Class Action Fairness Act of 2005 (CAFA). CAFA provides federal jurisdiction over certain class actions when the proposed classes collectively include more than 100 members, at least one class member is a citizen of a different state from a defendant, and the amount in controversy exceeds $5 million, excluding interest and costs. The credit union initially estimated the amount in controversy at $12,176,825.75 and later revised its estimate to $6,154,514.50.

Trigueros moved to remand, arguing that the credit union had not established the requirements for CAFA jurisdiction. She also argued that CAFA’s local-controversy and home-state exceptions applied, requested jurisdictional discovery concerning those exceptions, and sought sanctions.

Amount in Controversy

The court held that the credit union had to prove by a preponderance of the evidence—that is, show that it was more likely than not—that the amount in controversy exceeded $5 million. The court accepted several of the credit union’s estimates as plausible and supported by the evidence:

- $2,727,608.97 for meal- and rest-period premiums, based on an assumed 20% violation rate; - $487,073.30 for unpaid overtime, based on the credit union’s evidence about shift lengths and employee work status; and - $847,629.60 for waiting-time penalties, based on a 100% violation rate for employees who were terminated.

The court rejected the credit union’s wage-statement-penalty calculation because it included pay periods outside the one-year limitations period the court found applicable to those penalties. The court therefore found that the credit union had not proved any amount for wage-statement penalties.

The court also reduced the attorneys’ fee estimate. It concluded that fees related to meal- and rest-period premiums could not be included because the relevant California fee-shifting laws do not authorize fees for those claims. Using the remaining estimates for unpaid overtime and waiting-time penalties, the court calculated attorneys’ fees of $333,675.66. The court found that the total amount in controversy was $4,395,987.26, below CAFA’s $5 million threshold.

Ruling

Because the amount-in-controversy requirement was not met, the court concluded that it lacked jurisdiction under CAFA. It therefore did not reach the parties’ arguments concerning diversity of citizenship, the CAFA exceptions, or jurisdictional discovery.

Judge Beth Labson Freeman granted Trigueros’s motion to remand and remanded the case to the Superior Court of California for the County of Santa Clara. The court also denied Trigueros’s request for sanctions, finding that the credit union’s calculations and supporting declaration were not frivolous or made without a reasonable and competent inquiry. The clerk was directed to remand the action and close the federal case.