Lopez v. Eurofins Scientific, Inc
- Laurel Beeler
- 3:21-cv-08652
- U.S. District Court · Northern District of California
- 3
In Lopez v. Eurofins Scientific, Inc., Judge Beeler postponed preliminary approval, asking the parties to address potentially overbroad settlement-release language.
Rito Lopez, the proposed class members, and the defendants involved in the proposed settlement were affected because the court required further attention to the settlement’s release language before preliminary approval.
What happened
In Lopez v. Eurofins Scientific, Inc., Rito Lopez, a packer, brought a proposed class action against Eurofins Scientific, Environmental Sampling Supply, and TestAmerica Laboratories. He claimed they did not pay workers for time spent completing pre-shift temperature checks and COVID-19 screening questionnaires or waiting to clock back in after meal breaks. The claims included unpaid wages, inaccurate wage statements, missed meal and rest periods, late wage payments, civil penalties, and violations of California’s Unfair Competition Law.
The parties settled, and Lopez asked the court to preliminarily approve the settlement under Rule 23(e). The court identified a potential problem with the settlement’s release of claims, which covered claims alleged or that could have been alleged based on facts related to or ascertained in the case. The court asked the parties to explain by July 6 how they would address that language before the court preliminarily approved the settlement.
Judge Laurel Beeler did not preliminarily approve the settlement in this order. She scheduled a July 13 status hearing about the release language and suggested that a stipulated complaint might help address the issue.
The detailed version
- Lopez v. Eurofins Scientific, Inc · No. 3:21-cv-08652
- Laurel Beeler
- June 22, 2023
Background
Rito Lopez, who works as a packer, filed a putative class action against his alleged employers—Eurofins Scientific, Environmental Sampling Supply, and TestAmerica Laboratories. He alleged that the defendants failed to pay him and proposed class members for off-the-clock work, including completing temperature checks and COVID-19 screening questionnaires before clocking in and waiting in line to clock back in after meal breaks.
The complaint asserted claims for unpaid hours worked, minimum wages, overtime wages, accurate wage statements, meal and rest periods, timely payment of wages during employment and at termination, penalties under California’s Private Attorneys General Act, and violation of California’s Unfair Competition Law.
Settlement and Release
The parties settled the case. Lopez moved for preliminary approval of the proposed class settlement under Federal Rule of Civil Procedure 23(e), which governs court approval of class-action settlements.
The court explained that, under Ninth Circuit law, a settlement may release only claims based on the same factual basis as the claims resolved by the class action. The proposed release covered “any and all claims alleged, or that could have been alleged based on the facts alleged, related to, or ascertained in the Action.” The court found that the phrase “related to” could potentially release claims broader than those based on the same factual basis. It also found that “ascertained in” was nonspecific, although it might be acceptable with clarification.
Order
The court did not preliminarily approve the settlement in this order. Instead, it directed the parties to update the court by July 6, 2023, about how they planned to address the release language. The court also set a status hearing for July 13, 2023, on that issue and noted that a stipulated complaint might be part of the solution. The order was signed by United States Magistrate Judge Laurel Beeler on June 22, 2023.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.