De Sanctis v. Clean Harbors Environmental Services, Inc.
- Vince Chhabria
- 3:23-cv-05570
- U.S. District Court · Northern District of California
- 2
In De Sanctis v. Clean Harbors, Judge Chhabria denied remand because the amount in controversy exceeded $5 million.
Dino De Sanctis and Clean Harbors Environmental Services, Inc.; the case was not remanded by this order.
What happened
In De Sanctis v. Clean Harbors Environmental Services, Inc., Dino De Sanctis asked the federal court to send the case back to state court. The dispute involved whether the Class Action Fairness Act provided federal jurisdiction.
The court accepted Clean Harbors’s estimates, including one hour of unpaid overtime per eligible workweek, missed meal and rest breaks, and maximum waiting-time penalties for former employees. The court found these assumptions reasonable and conservative, and said they produced an amount in controversy more than twice the required $5 million.
Judge Vince Chhabria denied the motion to remand. The order therefore did not send the case back to state court.
The detailed version
- De Sanctis v. Clean Harbors Environmental Services, Inc. · No. 3:23-cv-05570
- Vince Chhabria
- Jan. 23, 2024
Background
Dino De Sanctis moved to remand the case, meaning he asked the federal court to return it to state court. Clean Harbors Environmental Services, Inc. relied on jurisdiction under the Class Action Fairness Act, which requires more than $5 million to be in controversy.
Court’s Analysis
Clean Harbors calculated the amount in controversy using three main assumptions: one hour of unpaid overtime for each eligible workweek; one missed meal break and one missed rest break for every five eligible work shifts; and maximum waiting-time penalties for all former employees during the class period.
The court held that these assumptions were reasonable in light of the complaint’s allegations. The court noted that Clean Harbors used only workweeks long enough to qualify for overtime and work shifts long enough to qualify for meal and rest breaks. It described the resulting estimates as conservative and said they produced an amount in controversy that more than doubled the Class Action Fairness Act’s $5 million requirement.
Disposition
Judge Vince Chhabria denied the motion to remand.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.