Sinclair v. Mike Bloomberg 2020, Inc.
- Laura Swain
- 1:20-cv-04528
- U.S. District Court · Southern District of New York
- 4
In Sinclair v. Mike Bloomberg 2020, Inc., Judge Swain denied class certification for lack of jurisdiction and denied the Campaign’s motion to strike as moot.
Rodney Sinclair and the proposed class of 37 people who worked as exempt-classified Campaign Field Organizers or similarly titled employees for Mike Bloomberg 2020, Inc. in Massachusetts; the ruling also made the Campaign’s motion to strike declarations from 22 out-of-state Field Organizers moot.
What happened
In Sinclair v. Mike Bloomberg 2020, Inc., Rodney Sinclair brought wage-law claims against Mike Bloomberg 2020, Inc., for himself and a proposed class of Massachusetts Campaign Field Organizers. He asked the court to certify that class.
The court determined that the proposed class had 37 people, fewer than the 100 required for federal jurisdiction under the Class Action Fairness Act. The court also found that the filings did not establish the complete diversity of citizenship that would be required under the ordinary diversity-jurisdiction statute if the class were certified.
Judge Swain denied Sinclair’s motion for class certification without prejudice to seeking to litigate the claims as a class in a procedural setting or forum with a jurisdictional basis. She denied the Campaign’s motion to strike declarations as moot because the court did not need to rely on them.
The detailed version
- Sinclair v. Mike Bloomberg 2020, Inc. · No. 1:20-cv-04528
- Laura Swain
- Aug. 25, 2023
Background
Rodney Sinclair filed a putative class action against Mike Bloomberg 2020, Inc. He asserted claims under the Massachusetts Wage Act and Massachusetts Minimum Fair Wage Laws on behalf of himself and other people who worked as exempt-classified Campaign Field Organizers, or similarly titled employees, for the Campaign in Massachusetts.
Sinclair moved for class certification under Federal Rule of Civil Procedure 23(a) and 23(b)(3). The Campaign separately moved to strike declarations from 22 people who had worked as Field Organizers for the Campaign in states other than Massachusetts.
Jurisdiction
The court explained that it must establish subject-matter jurisdiction, meaning its legal authority to hear the case, even though neither party had addressed the issue in its briefing. The complaint alleged ordinary diversity jurisdiction under 28 U.S.C. § 1332(a), which the court said was sufficient for Sinclair’s individual claims. But the court said the filings did not establish complete diversity for all proposed class members if the class were certified.
The court also considered the Class Action Fairness Act of 2005, which can provide federal jurisdiction over certain class actions when the proposed classes collectively include at least 100 members. Sinclair had indicated that the proposed class contained 37 people. Because that number was below 100, the court concluded that it would lack jurisdiction over the action if the class-certification motion were granted.
Rulings
The court denied Sinclair’s Motion for Class Certification, without prejudice to any application to litigate the claims on a class basis in a procedural context or forum where there would be a basis for jurisdiction. This ruling addressed jurisdiction and class certification; the opinion did not decide whether the alleged wage-law violations occurred or whether Sinclair’s claims had merit.
The court denied the Campaign’s Motion to Strike as moot because the class-certification motion was denied on jurisdictional grounds and the court did not rely on the challenged declarations. The case remained referred to Magistrate Judge Gorenstein for general pretrial management.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.