Monroe v. Hayward Unified School District

Background

Arnold Monroe and Donta Snowden worked as sanitation workers for both Hayward Unified School District and Fremont Unified School District. Monroe worked about 20 hours per week for Fremont and about 40 hours per week for Hayward until he retired in April 2021. Snowden worked about 40 hours per week for Hayward and about 25 hours per week for Fremont. Each plaintiff was covered by a collective-bargaining agreement governing employment with the districts.

The plaintiffs asserted three claims: breach of their collective-bargaining agreements, failure to pay minimum wages under the Fair Labor Standards Act (FLSA), and failure to pay overtime wages under the FLSA. They argued that the two school districts were one employer for purposes of calculating their weekly hours. The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), arguing that they were not joint employers.

Court’s Analysis

The court held that the decisive issue was whether the districts were one employer or separate employers. Under the FLSA, workers’ hours for multiple employers are combined when the employers are joint employers. The Ninth Circuit recognizes tests for vertical and horizontal joint employment. For horizontal joint employment, the relevant considerations include whether the employers arranged to share the employee’s services, whether one acted in the interest of the other concerning the employee, and whether they shared control.

The court concluded that the plaintiffs could not allege facts supporting joint employment because California law treats the districts as separate entities. Each district operates through its own governing board, and the two districts had separate boards of education. The districts therefore were legally separate in controlling, paying, and otherwise employing the plaintiffs. The court held that they were not joint employers under the FLSA regulations or either Ninth Circuit test.

The plaintiffs relied on California Government Code sections 20610, 20635, and 20635.1. The court determined that these provisions concern the calculation of California Public Employees’ Retirement System retirement benefits. They did not establish that the districts were one employer or impose FLSA or state-law overtime-payment obligations. The plaintiffs identified no other basis for treating the districts as one FLSA employer.

The court also found that the complaint alleged no facts supporting the breach-of-contract claim. The collective-bargaining agreements provided by the defendants addressed overtime for work performed for the particular district, and the plaintiffs had not alleged compliance with the agreements’ grievance procedures. The court noted that an amended contract claim might not be futile, but it would need to allege that the agreements applied to work performed for more than one district.

Disposition

Judge Laurel Beeler granted the defendants’ motions to dismiss. The court dismissed the FLSA claims without leave to amend because the plaintiffs’ joint-employer theory could not succeed as a matter of law. The court dismissed the contract claim without prejudice to filing an amended complaint in state court. The court explained that any amended complaint would contain only a state-law claim and that it would decline to exercise supplemental jurisdiction over that claim after dismissing the federal claims. The order resolved ECF Nos. 27 and 28.