Griselda Jauregui v. Roadrunner Transportation Serv

I. INTRODUCTION

We are asked in this case to review the district court’s order remanding a class action to California state court after it determined that the $5 million amount in controversy requirement of the Class Action Fairness Act was not met. Because the district court erred in its amount in controversy analysis by assigning a $0 valuation to several claims, we reverse and remand.

II. BACKGROUND

Plaintiff Griselda Jauregui filed a putative class action in California Superior Court against Defendant Roadrunner Transportation Services (Roadrunner) on behalf of all Roadrunner current and former California hourly workers. The complaint alleged numerous violations of California labor law focused primarily on wage and hour violations.

1 As listed by the district court, the alleged violations include:

(1) Labor Code §§ 510 and 1198 (unpaid overtime); (2) Labor Code §§ 226.7 and 512(a) (unpaid meal premiums); (3) Labor Code § 226.7 (unpaid rest period premiums); (4) Labor Code §§ 1194, 1197, and 1197.1 (unpaid minimum wages); (5) Labor Code §§ 201 and 202 (final wages not timely paid); (6) Labor Code § 204 (wages not timely paid during employment); (7) Labor Code § 226(a)…