Hughes v. United Airlines Inc.

Background

The plaintiffs filed a proposed class action alleging that United’s compensation practices for pilots and flight attendants violated the California Labor Code. The first amended complaint asserted claims for reporting-time pay, meal and rest breaks, reimbursement of business expenses, payroll-record maintenance, and unfair business practices. United removed the case to federal court under the Class Action Fairness Act, and the parties consented to jurisdiction by a magistrate judge.

United moved under Federal Rule of Civil Procedure 12(c) for partial judgment on the pleadings. That motion asks whether, accepting the complaint’s factual allegations as true, the defendant is entitled to judgment as a matter of law based on the pleadings.

Rulings on the Claims

Claim one—reporting-time pay. California Wage Order 9 generally requires payment when an employee reports to work but is not put to work, or works less than half a day. The wage order, however, excludes employees covered by a collective-bargaining agreement under the Railway Labor Act, except for provisions not relevant here. The court found that the pilots and flight attendants were covered by such collective-bargaining agreements. It also concluded that California Labor Code section 1198 did not independently create a reporting-time-pay requirement. The court therefore granted United judgment on claim one in full.

Claim four—business-expense reimbursement. To the extent this claim was based on Wage Order 9’s provision concerning employer-provided and maintained uniforms, the court held that the Railway Labor Act exemption applied. The court granted United judgment on that portion of claim four.

Claim five—payroll records. The court held that Labor Code sections 1174 and 1174.5 do not provide a private right of action, meaning these provisions do not authorize an employee to bring an individual lawsuit to enforce them. The court also found that the plaintiffs’ allegations were conclusions rather than supporting facts. It dismissed claim five.

Claim seven—unfair business practices. The plaintiffs conceded that this claim was based on claims one, four, and five. The court granted United judgment on claim seven to the extent it was based on those claims. The court also granted judgment on the plaintiffs’ requests for waiting-time penalties under Labor Code section 203 and recordkeeping penalties under section 1174.5 because the unfair-business-practices law provides only restitutionary remedies.

Claims two and three—meal and rest breaks. California Labor Code section 512.2 excludes airline crew members covered by a Railway Labor Act collective-bargaining agreement from the meal-and-rest-break requirements when the agreement addresses meal and rest periods. The court found that the flight attendants’ agreement addressed those periods. Because there was no ongoing statutory right supporting an injunction for those flight attendants, the court granted United judgment on the request for injunctive relief for claims two and three. The order did not dispose of those claims in their entirety.

Disposition

The court granted United judgment as a matter of law: on claim one in full; on claim four to the extent it concerned uniform expenses under Wage Order 9; on claim five in full; on claim seven to the specified extent; and on claims two and three as to flight attendants’ requests for injunctive relief. The court stated that these matters could not be cured by amendment and that the dismissal was with prejudice. The order disposed of United’s motion, ECF No. 36.