Williams v. Amazon.com Services LLC
- Vince Chhabria
- 3:22-cv-01892
- U.S. District Court · Northern District of California
- 2
Judge Chhabria partly granted and partly denied Williams v. Amazon's dismissal motion, keeping expense-reimbursement and labor-penalty claims alive but dismissing the unfair-competition claim with leave to amend.
David G Williams and Amazon.com Services LLC; Williams's expense-reimbursement and PAGA claims remain in the case, while his UCL claim was dismissed with leave to amend.
What happened
In Williams v. Amazon.com Services LLC, David G Williams alleged that he incurred work-related expenses while working from home during the COVID-19 pandemic, including costs for physical space, internet, and electricity.
Williams claimed Amazon had to reimburse those expenses under California law. Amazon argued that government stay-at-home orders, rather than Amazon, caused the expenses, and Williams had not expressly requested reimbursement. Williams also brought an unfair-competition claim and a PAGA claim.
Judge Vince Chhabria granted in part and denied in part the motion to dismiss, with leave to amend. The court allowed Williams's expense-reimbursement claim to proceed, kept the PAGA claim in the case, and dismissed the unfair-competition claim because the complaint did not allege that Williams lacked an adequate legal remedy.
The detailed version
- Williams v. Amazon.com Services LLC · No. 3:22-cv-01892
- Vince Chhabria
- June 1, 2022
Background
David G Williams alleged that he worked from home during the COVID-19 pandemic and incurred expenses connected to his work for Amazon.com Services LLC. The complaint identified him as a senior software development engineer whose duties included developing software, writing and reviewing design documents, conducting code reviews, and being on call for production systems. Williams alleged that performing those duties required physical space, internet service, and electricity.
The motion to dismiss challenged Williams's California Labor Code section 2802 expense-reimbursement claim, his claim under California's unfair-competition law (the UCL claim), and his PAGA claim.
Expense-Reimbursement Claim
The court held that Williams plausibly stated a claim under California Labor Code section 2802. That law concerns reimbursement for expenses incurred as a direct consequence of an employee's duties or compliance with an employer's directions.
Amazon argued that any expenses resulted from government stay-at-home orders rather than Amazon's conduct. The court rejected that argument at the pleading stage, explaining that Amazon could still be liable if Williams incurred the expenses because he was expected to continue working from home. The court also found that Williams plausibly alleged the expenses were necessary for his job and that Amazon knew, or had reason to know, that software development engineers working from home were incurring basic work-related costs. The court did not require Williams to have expressly requested reimbursement at this stage.
UCL Claim
The court dismissed the UCL claim with leave to amend. The complaint did not allege that Williams lacked an adequate remedy at law, a condition relevant to obtaining equitable relief.
PAGA Claim
The court stated that Williams's PAGA claim rose and fell with his Labor Code section 2802 claim. Because the section 2802 claim remained viable, the PAGA claim also remained in the action.
Disposition
The court granted in part and denied in part the motion to dismiss with leave to amend. If Williams chose to file an amended complaint, it was due within 14 days of the order, and a response to the original or amended complaint was due 14 days after that.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.