Barnett v. City of San Jose

CourtDistrict Court, N.D. California
DecidedJanuary 31, 2025
Docket3:18-cv-01383
StatusUnknown

This text of Barnett v. City of San Jose (Barnett v. City of San Jose) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Barnett v. City of San Jose, (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 DAVID BARNETT, et al., Case No. 18-cv-01383-JD

8 Plaintiffs, FINDINGS OF FACT AND 9 v. CONCLUSIONS OF LAW

10 CITY OF SAN JOSE, Defendant. 11

12 13 Plaintiffs are firefighters employed by defendant City of San Jose (City). They sued the 14 City for unpaid overtime they allege the City owes them under the Fair Labor Standards Act 15 (FLSA), Pub. L. No. 75-718, 52 Stat. 1060 (1938) (codified as amended at 29 U.S.C. §§ 201 et 16 seq.). See generally Dkt. No. 46 (SAC). In a nutshell, the FLSA establishes, among other things, 17 a minimum amount that firefighters must be compensated for overtime work. The City pays the 18 firefighters pursuant to a collective bargaining agreement. To ensure compliance with the FLSA, 19 the City compares at the end of each relevant period the amount paid under the agreement to the 20 amount it is obligated to pay under the statute. If the amount paid per the agreement is below the 21 amount due under the FLSA, the City pays the firefighter the difference; if the amount per the 22 agreement is greater, the City takes no further action. Plaintiffs say the City’s approach 23 shortchanged them and paid less than the FLSA required. 24 Although this may sound relatively simple, the case has been beset by tortuous (and on 25 occasion torturous) immersions into overtime pay calculations, spreadsheets, endless numerical 26 tables, and the like. At multiple times in the litigation, even the lawyers for the parties seemed 27 flummoxed by the math and unable to explain in plain and simple terms what the actual 1 be attributable to the fact that, as many courts have noted, determining FLSA pay rates can be a 2 perplexing exercise. 3 After unsuccessful attempts at resolving the dispute in motion hearings, the Court 4 concluded that a bench trial with witnesses and evidence was warranted. Dkt. Nos. 107, 127. 5 Unfortunately, the parties chose to treat the bench trial as another motion hearing and did not 6 proffer a single witness who might have brough clarity to the case. Dkt. No. 136. The trial 7 consisted of attorney argument and admission of the parties’ stipulations of fact and documents 8 into the record, most of which were again comprised of masses of numbers without explanatory 9 context. See Dkt. Nos. 136, 140. 10 The Court advised the parties that the bench trial decision would be based solely on the 11 evidence admitted at trial. Dkt. No. 137. The ensuing findings of fact and conclusions of law are 12 based on the trial evidence, the parties’ trial briefs, and post-trial submissions. See Dkt. Nos. 83, 13 90, 101, 115-16, 136, 140, 144-45. 14 An almost-identical lawsuit was previously brought in this district by different San Jose 15 firefighters against the City. These plaintiffs were part of that case until it was decertified, at 16 which point they decided to proceed separately. Dkt. No. 46 ¶ 9. In that case, Wallace v. City of 17 San Jose, summary judgment was entered for the City, and the Ninth Circuit affirmed. Here, the 18 City did not pursue issue preclusion in any form. The result here is different. Plaintiffs have met 19 their burden of establishing that the City underpaid them during certain work periods and so 20 violated the FLSA. 21 FINDINGS OF FACT 22 I. THE CITY’S METHOD OF PAYING ITS FIREFIGHTERS 23 1. The Memorandum of Agreement (MOA) (i.e., the collective bargaining agreement) 24 between the City and the firefighters’ union memorializes the terms and conditions of firefighter 25 employment, including compensation, for fiscal years July 1, 2014, and June 30, 2018. Dkt. 26 No. 136, Stipulation of Undisputed Facts (SUF) No. 1; Dkt No. 140-11 (Trial Exh. 857) (MOA). 27 1 2. Under the MOA, firefighters who are assigned to 24-hour work shifts (which 2 includes most of the plaintiffs here) are required to work at least an average of 56 scheduled hours 3 per week. SUF No. 2; MOA § 14.3. 4 3. The firefighters are paid biweekly, meaning every two weeks (the pay period or 5 MOA pay period). SUF No. 3. There are various firefighter classifications, and the “MOA sets a 6 ‘salary schedule’ providing for biweekly salary payments” for each firefighter classification based 7 on 112 hours of work. SUF Nos. 5, 6; MOA § 30.1 & Exhibit I thereto. 8 4. Plaintiffs are salaried employees for purposes of the FLSA. The City pays 9 plaintiffs their set salaries “regardless of the number of [scheduled] hours employees actually 10 work,” an arrangement negotiated by the union and City to “accommodate the firefighters’ request 11 for consistency and predictability in their pay checks.” SUF No. 5. The payment schedule jointly 12 submitted into evidence with the MOA (MOA Exhibit I) is entitled “2014-2018 IAFF Salary 13 Schedule.” MOA Exhibit I. Plaintiffs’ paystubs indicate that their biweekly “pay rate” is pegged 14 to an unchanging 112 hour “Quantity” instead of a variable number of “Hours.” Dkt. Nos. 140-3 15 at ECF 2-3 (Trial Exh. 142); 140-4 at ECF 2-3 (Trial Exh. 143). 16 5. In addition to the amounts identified in the salary schedule, the City also pays 17 firefighters “premium” or “add-on” payments. SUF No. 10. The add-on payments are additional 18 rewards or incentives for firefighters with certain skills, for example emergency medical training 19 or language skills. See generally MOA § 5. Although disbursed as lump-sum payments at the end 20 of each pay period, a number of these add-on payments are essentially salary enhancements. 21 6. The MOA also provides for premium pay for overtime hours, which will be 22 denoted here as “contractual overtime.” Firefighters assigned to a 56-hour-per-week schedule 23 who work more than 24 hours at a time earn 1.5 times (1.5x) their “base hourly rate” for the extra 24 hours worked. MOA § 14.5; SUF NO. 7. 25 7. The base hourly rate is based solely on the amounts set forth in the salary schedule, 26 and so is exclusive of any add-on payments. The base hourly rate may be calculated by two 27 mathematically equivalent ways: (1) dividing the firefighter’s biweekly salary by the set number 1 of 112; or (2) doubling the firefighter’s biweekly salary and dividing that by the set number of 2 224. SUF No. 5; MOA Exhibit I. 3 8. Plaintiffs are eligible for contractual overtime for working extra unscheduled hours, 4 which are hours “they work outside their regularly[ ]scheduled work shifts.” SUF No. 14. 5 9. Consequently, contractual overtime is due even if the firefighter worked less than 6 112 scheduled hours in a two-week MOA pay period. SUF No. 14. This can happen when a 7 firefighter takes vacation or sick time at one point in the pay period (and so works less than 112 8 scheduled hours) but ends up working extra non-scheduled hours at another point in the pay 9 period. MOA § 14.9; SUF Nos. 8, 14. 10 10. The FLSA guarantees premium pay to plaintiffs when they work more than 24 11 hours at a time or more than 212 hours in a 28-day work period (FLSA work period or work 12 period). For clarity, the Court refers to this overtime pay under the statute as “FLSA overtime.” 13 FLSA overtime differs from contractual overtime in two relevant respects: (1) FLSA overtime 14 only kicks in when the number of hours actually worked exceeds 212 hours in a given work period 15 (without considering vacation or sick time); (2) FLSA overtime is paid at a higher rate than 16 contractual overtime because it includes both the biweekly salary and certain add-on payments (to 17 be discussed in greater detail later). SUF No. 10. Put more plainly, contractual overtime is paid 18 more often but at a lower rate than FLSA overtime. 19 11. The City recognizes that FLSA overtime differs from contractual overtime. It uses 20 a software program called PeopleSoft to check its compliance with the statute. Dkt. No. 140-1 21 (Trial Exh.

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Barnett v. City of San Jose, Counsel Stack Legal Research, https://law.counselstack.com/opinion/barnett-v-city-of-san-jose-cand-2025.