Nguyen v. Smiths Detection Inc.

Background

Viet Nguyen sued Smiths Detection Inc. in Alameda County Superior Court on behalf of himself and a proposed class of non-exempt hourly employees. The complaint asserted wage-and-hour claims under California law. Smiths Detection removed the case to federal court under the Class Action Fairness Act (CAFA), which allows certain class actions to be heard in federal court when statutory requirements are met.

Nguyen moved to remand, meaning he asked the federal court to return the case to state court. He argued that Smiths Detection had not plausibly established CAFA’s requirement that more than $5 million be in controversy. Nguyen did not dispute CAFA’s minimum-diversity or class-size requirements. The court also considered and denied a request for judicial notice, stating that it did not rely on the submitted materials.

Amount in Controversy

The court held that Smiths Detection had to plausibly show that it was reasonably possible for the potential liability to exceed $5 million; it did not have to prove that the alleged violations actually occurred at the assumed rates.

The court overruled Nguyen’s objection to a declaration from Smiths Detection’s vice president of human resources. The declaration relied on company payroll records and identified approximately 191 potential class members employed in California during the relevant period. Smiths Detection estimated approximately $1.79 million in controversy for meal-break violations, using a 60-percent violation rate. The court found that estimate reasonable because the complaint alleged systematic and consistent meal-break violations and automatic deductions of 30 minutes of pay.

For the rest-break claim, Smiths Detection estimated approximately $2.98 million using a 100-percent violation rate. The court found that assumption reasonable in light of the complaint’s allegation that the employees were never given the opportunity to take uninterrupted rest breaks.

Together, the meal- and rest-break claims placed approximately $4.77 million in controversy. The court added approximately $1.19 million for attorney fees and costs, based on a 25-percent estimate. Because the complaint requested reasonable attorney fees, the court concluded that the total amount in controversy exceeded CAFA’s $5 million threshold. The court did not decide how much unpaid wages or waiting-time penalties might add to the amount.

Disposition

The court ruled that the case was properly removed to federal court under CAFA and denied remand. It directed the parties to schedule an initial case-management conference in June 2022. The opinion’s judge signature is not fully clear in the provided text and appears to read “JAMES ATO”; no judge name was otherwise supplied.