Miguel-Sanchez v. Mesa Packing, LLC

Background

William Miguel-Sanchez, Luis Antonio Meza-Estrada, and Sergio Jimenez-Cruz brought a wage-and-hour class action against Mesa Packing, LLC. They alleged that Mesa failed to pay agricultural field workers for pre-shift exercises and other preparatory work; did not accurately record field arrival times, piece-rate work, or work performed before scheduled shifts; automatically deducted 30-minute meal periods even when workers worked during them; failed to pay for missed, late, or shortened meal and rest periods; provided inaccurate paystubs; required workers to supply headlamps; and sometimes sent workers home without at least half a usual day’s work.

The alleged claims arose under the California Labor Code, the Migrant and Seasonal Agricultural Workers Protection Act, and California’s Unfair Competition Law. The court had previously conditionally certified a settlement class and preliminarily approved the proposed settlement. That preliminary approval was briefly withdrawn and later reinstated after the proposed consent judgment was changed to conform its third-party release language to representations made to the court.

Settlement and Notice

The parties agreed to a non-reversionary settlement—that is, a settlement fund that would not return undistributed money to Mesa. The agreement provided for a gross settlement amount of $1,850,000. From that amount, the court-approved allocations included up to $400,000 for attorneys’ fees, up to $7,500 for litigation costs, and $7,500 incentive awards for each named plaintiff. The remaining $1,420,000 was to be distributed among participating class members based on the number of pay periods in which each performed piece work for Mesa during the class period, February 4, 2016, through October 23, 2020. Mesa separately agreed to pay settlement-administration costs. Any uncashed settlement funds would go to Salud Para La Gente as a charitable distribution.

Mesa also agreed to implement and enforce employment practices addressing the alleged violations, including providing full meal and rest breaks, tracking and paying for pre-shift work and other nonproductive work, paying for rest periods, and providing tools and equipment such as headlamps.

The final class consisted of 699 people. Of the 699 mailed notices, 613 class members—87.7 percent—were known to have received actual notice through mailed notices, address tracing, WhatsApp messages, or updated addresses. The administrator also provided a website and toll-free telephone line. Two class members requested exclusion, and no objections were filed or presented at the fairness hearing.

Court’s Analysis

The court determined that the requirements for final class certification under Federal Rule of Civil Procedure 23 were met. The certified class included people who worked for Mesa as non-exempt piece-rate workers during the class period and alleged the California-law violations described in claims one through ten of the complaint. The court found that the notice procedure was reasonably calculated to inform class members and was the best notice available under the circumstances.

For settlement approval, the court considered whether the agreement was fair, reasonable, and adequate. It found that the risks of continued litigation—including arbitration agreements affecting two named plaintiffs and about half of the proposed class, and the risk that class certification might not be maintained—supported settlement. The court also found the settlement amount fair: the gross amount was approximately 46 percent of Mesa’s estimated maximum potential liability, and the net amount was approximately 35 percent. The court found that the parties had enough information to negotiate despite limited formal discovery, that class counsel were experienced, that the class reaction was favorable, and that the distribution plan treated class members equitably.

The court also examined whether the attorneys’ fee arrangement showed signs of collusion or reduced the class’s recovery. It found that the requested $400,000 fee was 21.6 percent of the global settlement fund and 28.2 percent of the potential actual payment to the class. The court found no improper provision requiring Mesa to agree to a specific fee amount or allowing unawarded fees to return to Mesa. It concluded that the settlement was fair, adequate, and reasonable.

Fees, Costs, and Incentive Awards

The court used the percentage-of-the-fund method to evaluate the requested attorneys’ fees and cross-checked the result against the lodestar method. A lodestar is calculated by multiplying reasonable hours by a reasonable hourly rate. The court found reasonable hourly rates of $725 for Dawson Morton and $750 for Santos Gomez. It found that class counsel’s approximately 297 hours were reasonable. Their combined lodestar was $217,337.50, and the requested fee represented a 1.84 multiplier, which the court found acceptable.

The court awarded $4,315.74 in litigation costs for filing and service fees, copying and mailing, legal research, mediation, and translation. It also approved $7,500 incentive awards for each named plaintiff, finding that their time, efforts, stated difficulties, and risks associated with bringing the action supported those awards.

Disposition

The court granted plaintiffs’ motion for final approval of the class action settlement. It also granted plaintiffs’ motion for attorneys’ fees, costs, and incentive awards. The court awarded $400,000 in attorneys’ fees, $4,315.74 in litigation costs, and $7,500 to each named plaintiff. The opinion approved the settlement rather than deciding whether Mesa actually committed the alleged wage-and-hour violations.