Anderson v. Starbucks Corporation

Background

Starbucks moved to dismiss claims in the second amended complaint. The opinion addressed three issues: whether the claims were filed too late, whether the plaintiffs sought duplicative recovery for wage statement and unpaid-wages claims, and whether certain plaintiffs satisfied the administrative exhaustion requirements for claims under California’s Private Attorneys General Act (PAGA).

The original complaint was filed in Alameda County Superior Court on June 27, 2019. The court applied the relation-back rule, which allows an amended pleading to use the original filing date when the amended claims arise from the same conduct, transaction, or occurrence described in the original pleading.

Timeliness and Relation Back

The court denied dismissal on timeliness grounds. It held that the allegations and claims in the second amended complaint were related to and within the scope of the original complaint. The court also declined to decide at the motion-to-dismiss stage whether some named plaintiffs’ claims might fall outside applicable limitation periods. Starbucks could renew that request at summary judgment if supported by the record.

Duplicative Recovery

The court also denied Starbucks’s argument concerning potentially duplicative recovery for wage statement and unpaid-wages claims as premature. It said the plaintiffs could plead alternative theories of liability under Federal Rule of Civil Procedure 8(d)(2). The court stated that it would address the proper measure of recovery as the case developed and would not permit an impermissible double recovery.

PAGA Claims and Disposition

Starbucks argued that several named plaintiffs had not alleged compliance with PAGA’s administrative exhaustion requirements. The plaintiffs did not address that argument in their opposition brief, which the court treated as an effective concession. The court ruled that Luke Adelman, Elizabeth Anderson, Ellesse Anderson, Sherri Bradley, Amanda Brekke, Jacqueline Foster, Omar Garland, Hannah Rothschild, Jordone Shane-Sanchez, and Kevin Steinbeck could not maintain PAGA claims.

The order does not state an overall disposition using the phrase “granted in part” or “denied in part.” It expressly says that dismissal on timeliness grounds was denied and that the duplicative-recovery argument was denied as premature, while separately ruling that the ten listed plaintiffs could not maintain PAGA claims.