Price v. Wells Fargo & Company

Background

The plaintiffs brought state-law wage-and-hour claims against their current and former employer, Wells Fargo & Company and Wells Fargo Bank, National Association. Their ninth claim sought relief under California’s Unfair Competition Law, California Business and Professions Code section 17200 and related provisions. The UCL claim requested both equitable restitution for past losses and prospective injunctive relief to correct allegedly unlawful practices going forward.

Wells Fargo moved for partial judgment on the pleadings. This type of motion asks the court to decide whether the claims may proceed based on the pleadings filed in the case. Wells Fargo argued that the plaintiffs’ UCL claim was barred because they had an adequate remedy through money damages under California’s Labor Code.

Court’s analysis

The court explained that federal courts may grant equitable relief only when the plaintiff lacks an adequate remedy at law. The plaintiffs did not dispute that their Labor Code claims provided an adequate legal remedy for the UCL restitution claim. The court therefore concluded that it lacked equitable jurisdiction over that claim.

The court reached a different conclusion about prospective injunctive relief. Although Wells Fargo argued that available damages barred all equitable relief, the court held that Wells Fargo had not shown that damages were an adequate remedy for the plaintiffs’ allegations that unlawful practices might continue. The plaintiffs had therefore adequately alleged a basis to pursue an injunction addressing future compensation and meal-and-rest-break practices.

Disposition

The court granted Wells Fargo’s motion for judgment on the pleadings as to the plaintiffs’ equitable UCL restitution claim and dismissed that claim without prejudice to pursuing it in state court. The court denied the motion as to the plaintiffs’ UCL injunctive-relief claim. The order disposed of Docket No. 35 and set a further video case-management conference.