Miguel-Sanchez v. Mesa Packing, LLC

Background

The court had previously granted final approval to a class-action settlement. It later extended the period for class payments so the settlement administrator could conduct additional searches and pay any class members who could be located.

On October 14, 2022, the plaintiffs filed an amended final payment report. The report stated that 17 additional class members had been located and paid. It also stated that $65,994.50 remained in the settlement fund for distribution to the previously approved cy pres recipient, Salud Para La Gente (Salud), in Watsonville, California.

The plaintiffs asked the court to order payment of the remaining funds to Salud. Alternatively, they proposed distributing the funds proportionally among the 548 class members who had already been paid. The plaintiffs reported that such payments would be minimal: the average additional payment would be less than $120, and one-quarter of the payments would be less than $15. The opinion also states that an additional distribution would incur further costs, although the available text does not specify the amount.

Court’s analysis

Cy pres is a method for distributing unclaimed class-settlement funds to the next best group of beneficiaries when direct payments are not appropriate or practical. The court explained that the recipient should promote the goals of the laws involved and serve the interests of class members.

The claims in this case arose under the California Labor Code, the Migrant and Seasonal Agricultural Workers Protection Act, and California’s Unfair Competition Law. The court found that Salud provided healthcare services in California’s Pájaro Valley without regard to a patient’s ability to pay. It had 10 clinic sites and nearly 30,000 patients, approximately 75% of whom did not speak English.

The court found an indirect connection between Salud and the objectives of the laws at issue. In particular, the Agricultural Workers Protection Act protects migrant and seasonal agricultural workers, many of whom are low income, by establishing employment standards involving wages, housing, transportation, disclosures, and recordkeeping. Although Salud did not directly work on housing or transportation issues, the court found that it served the same community the Act seeks to protect.

The court also found that Salud served the interests of the class members because it provided healthcare to people living in the Pájaro Valley, where many class members worked. The court noted that Salud began as a free clinic serving farmworkers and their families. It also noted that no one had objected to the settlement agreement during the approval process.

Ruling

The court ordered that the net amount of $65,994.50 be paid to Salud Para La Gente in Watsonville, California. Judge Virginia K. Demarchi signed the order directing distribution of the cy pres funds.