Huynh v. Jabil Inc.

Background

Strong Huynh sued Jabil Inc. on behalf of himself and a proposed class of current and former hourly-paid, non-exempt employees who worked for Jabil in California. Huynh alleged that Jabil required employees to work while clocked out during meal and rest breaks, failed to provide required additional breaks, failed to include shift premiums and other compensation when calculating regular pay, failed to pay all wages due at separation, provided inaccurate wage statements, failed to maintain accurate payroll records, and did not reimburse required use of personal cellphones for work duties.

The amended complaint asserted seven causes of action under California law: unpaid wages; missed meal periods; missed rest periods; waiting-time penalties for unpaid wages at separation; inaccurate wage statements and payroll records; reimbursement of business expenses; and unfair or unlawful business practices under California’s Unfair Competition Law. Jabil moved to dismiss all claims for failure to state a plausible claim and moved to strike the proposed class allegations.

Ruling on the Pleadings

Under Federal Rule of Civil Procedure 12(b)(6), the court considered whether the complaint alleged enough facts to make each claim plausible, accepting well-pleaded allegations as true for this stage of the case.

The court held that Huynh plausibly alleged most of his unpaid-wage claim. His allegations about off-the-clock work, missed or interrupted breaks, specific shift lengths, and the failure to include a shift premium in the regular rate of pay were sufficient. The court dismissed Huynh’s reliance on Labor Code section 204 with leave to amend because he did not allege that Jabil failed to pay wages twice monthly. It also dismissed his reliance on section 206 with leave to amend because he did not allege a qualifying wage dispute, an attempt to condition payment on a waiver, or a proceeding before the Labor Commissioner. The court denied Jabil’s motion as to the other Labor Code provisions supporting the unpaid-wage claim.

The court denied the motion to dismiss the meal-period and rest-period claims. Huynh alleged that supervisors requested work during breaks, that Jabil failed to schedule additional breaks for sufficiently long shifts, and that understaffing contributed to the problem. The court also denied the motion to dismiss the waiting-time-penalty claim because the underlying unpaid-wage and break claims were adequately pleaded.

The court granted the motion to dismiss the portion of the wage-statement and records claim based on Labor Code section 1174. It concluded that section 1174 did not provide an individual employee with a private right of action to enforce the employer’s record-maintenance duties. The claim based on inaccurate itemized wage statements remained.

The court denied the motion to dismiss the expense-reimbursement claim. Huynh alleged that Jabil required him to use his personal cellphone to provide updates about machinery and scheduling without reimbursement.

The court allowed the Unfair Competition Law claim to proceed to the extent it was based on the adequately pleaded underlying claims. It dismissed the request for injunctive relief because Huynh was no longer employed by Jabil and therefore lacked standing to seek that relief for the proposed class. The court also granted Jabil’s motion concerning the Unfair Competition Law claim with leave to amend so Huynh could allege that his legal remedies were inadequate, as required for alternative equitable relief.

Class Allegations

The court denied Jabil’s motion to strike the class allegations. It explained that striking class allegations at the pleading stage is generally premature and appropriate only when the defendant shows that no class could be certified. Huynh’s allegations about Jabil’s understaffing, break practices, pay calculations, and failure to reimburse expenses were sufficient at this stage to support an inference that similar practices affected other California employees.

Disposition

The court denied Jabil’s motion to dismiss except that it dismissed, with leave to amend, Huynh’s reliance on Labor Code sections 204 and 206; dismissed the section 1174 records claim; and dismissed the Unfair Competition Law claim with leave to amend regarding the inadequacy of legal remedies. The court denied the motion to strike the class allegations. Any further amended complaint was due within 21 days of the order.