Alcazar v. California United Mechanical, Inc..
- Haywood Gilliam
- 3:21-cv-09003
- U.S. District Court · Northern District of California
- 8
In Alcazar v. California United Mechanical, Judge Gilliam denied remand, finding federal labor-law preemption created jurisdiction over Alcazar’s wage claims.
Esteban Alcazar, California United Mechanical, Inc., and the employees included in the proposed class action.
What happened
In Alcazar v. California United Mechanical, Esteban Alcazar sued California United Mechanical, Inc. in California state court, alleging unpaid wages, overtime, meal and rest period premiums, inaccurate wage statements, unreimbursed expenses, and unfair business practices on behalf of himself and other employees.
The company moved the case to federal court, arguing that a collective bargaining agreement and federal labor law controlled Alcazar’s overtime claim. Alcazar asked the federal court to send the case back to state court.
Judge Haywood S. Gilliam, Jr. denied the motion to remand. He ruled that the collective bargaining agreement met California’s requirements for controlling overtime claims, so federal labor law preempted that claim and gave the court federal-question jurisdiction; he also exercised supplemental jurisdiction over the remaining state-law claims.
The detailed version
- Alcazar v. California United Mechanical, Inc.. · No. 3:21-cv-09003
- Haywood Gilliam
- Aug. 10, 2022
Background
Esteban Alcazar filed a proposed wage-and-hour class action against California United Mechanical, Inc. in Santa Clara County Superior Court. He alleged that the company failed to pay him for overtime, missed meal periods, missed rest periods, and other wages. He also alleged that the company failed to provide accurate payroll records and wage statements, reimburse business expenses, provide legally required meal and rest periods, and pay all wages due when his employment ended.
The company removed the case to federal court under Section 301 of the Labor Management Relations Act, arguing that the statute preempted Alcazar’s California-law claims. Alcazar moved to remand, meaning he asked the federal court to return the case to state court.
LMRA Preemption
The court applied the Ninth Circuit’s two-step test for Section 301 preemption. First, it asked whether the claimed right existed only because of the collective bargaining agreement. If not, it would ask whether resolving the claim substantially depended on interpreting that agreement.
The court focused on Alcazar’s overtime claim under California Labor Code sections 510 and 1198 and related wage orders. Under Ninth Circuit precedent, an overtime claim is controlled by a collective bargaining agreement when the agreement meets the requirements of California Labor Code section 514.
The court found that those requirements were met. Alcazar was covered by a valid collective bargaining agreement between his union and an employers’ association of which the company was a member. The agreement addressed wages, hours, and working conditions; provided premium rates for overtime; and provided regular hourly rates more than 30 percent above the applicable California minimum wage. The court also found that the wage schedules covered the relevant employee classifications, including Building Trades, Light Commercial, Residential, and Industrial.
The court therefore held that the collective bargaining agreement controlled Alcazar’s overtime claim and that Section 301 of the Labor Management Relations Act preempted it. That preemption gave the federal court federal-question jurisdiction over the overtime claim.
Supplemental Jurisdiction
The company asked the court to exercise supplemental jurisdiction over Alcazar’s remaining California-law claims. Supplemental jurisdiction allows a federal court to hear related state-law claims when they arise from the same underlying facts as a federal claim.
The court agreed because the remaining claims arose from the same working conditions and employment relationship during the same period as the overtime claim. The court found that the claims shared a common set of operative facts and would ordinarily be tried together.
Disposition
Judge Haywood S. Gilliam, Jr. denied Alcazar’s motion to remand. The court also scheduled a telephonic case-management conference and stated that it intended to set a schedule, including a class-certification hearing no later than August 2023. The opinion addressed federal jurisdiction and preemption; it did not decide whether Alcazar ultimately proved his wage-and-hour claims.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.