in Re: Papa John's Employee and Franchisee Employee Antitrust Litigation

CourtDistrict Court, W.D. Kentucky
DecidedAugust 7, 2025
Docket3:18-cv-00825
StatusUnknown

This text of in Re: Papa John's Employee and Franchisee Employee Antitrust Litigation (in Re: Papa John's Employee and Franchisee Employee Antitrust Litigation) is published on Counsel Stack Legal Research, covering District Court, W.D. Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
in Re: Papa John's Employee and Franchisee Employee Antitrust Litigation, (W.D. Ky. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY LOUISVILLE DIVISION In Re: Papa John’s Employee and Franchisee Employee Antitrust Litigation

Case No. 3:18-cv-825-BJB ***** OPINION & ORDER PRELIMINARILY APPROVING SETTLEMENT CLASS & AUTHORIZING NOTICE Ashley Page is the sole representative of a putative antitrust class of pizza- chain employees subject to franchise-wide no-poach provisions. She has filed an amended motion for preliminary approval of a classwide settlement with Papa John’s International and Papa John’s USA.1 DN 239. The Court previously issued an opinion (DN 227) denying Page’s initial motion (DN 202) for preliminary approval of this settlement. A fuller account of the allegations in this case and the reasons why preliminary approval was premature can be found in that opinion. It explains why the Court could likely approve the proposed settlement under Rule 23(e)(2), but not necessarily certify the class under Rule 23(a) and (b)(3)—at least not based on the record then before the Court. Opinion at 3, 4–8. That order requested additional information on whether Page’s claims were typical of the class, whether her representation was adequate, and whether common questions of law or fact predominated. Id. at 5–7. Under Rule 23(e)(1)(B), a court should preliminarily approve a classwide settlement and direct notice to class members if “the court will likely be able to … approve the proposal under Rule 23(e)(2) and certify the class for purposes of judgment on the proposal.” Page’s amended motion—boosted by a later-filed supplement (DN 253) and information provided during a hearing (DN 245)—clears these hurdles, though without tremendous room to spare. Whether the Court ultimately approves the proposed settlement—after hearing from potential objectors—is of course a different question. So for now the Court preliminarily approves the request for a classwide settlement, approves the process for notifying potential class members, and sets a schedule for interested parties to object or

1 The complaint explains that the two corporate entities “operate as a single entity” “out of the same location” with “the same directors and executives.” Amended Complaint (DN 54) ¶¶ 22–23. For purposes of this motion, the parties identify no relevant difference between the two Defendants and the remainder of the opinion refers to them collectively as Papa John’s. comment before a fairness hearing and ultimate determination regarding class- settlement approval. A. Rule 23(e)(2). The Court previously held that it would “likely be able to … approve the proposal under Rule 23(e)(2),” Opinion at 4, and this order will not disturb that holding. Upon further review of the Settlement Agreement and supplemental filings, however, two potential issues may merit attention at or before the final fairness hearing. 1. The Settlement Agreement imposes more onerous requirements on putative class members to opt out or object than to receive notice of the settlement. Under the Agreement, email is the primary method for notifying absent class members of the proposed settlement: “Class Counsel and Defendants’ Counsel shall work together to develop the content of an email notice that the Claims Administrator will distribute ….” Settlement Agreement (DN 202-2) ¶ 6.2. Notice is mailed to class members only if “the Claims Administrator is unable to locate working email addresses ….” ¶ 6.3. And class members can submit claims through a website. ¶ 6.6. But those wishing to object or opt out must send snail mail to the Claims Administrator. ¶¶ 6.10, 7.2. Why would email work for some but not all purposes? Needless to say, Americans use email for all manner of legal and business dealings in 2024—now three decades out from the launch of AOL and the founding of Prodigy. Perhaps good reasons exist for this delay and asymmetry. But none are apparent from the face of the settlement and court filings. At least one other district court has rejected a similarly skewed proposed settlement: “requiring … class members to opt out by mailing a hard copy letter … serves little purpose but to burden those who wish to opt out. In a world where [the Defendants] can … administer settlement claims electronically … [Defendants] can assuredly process opt outs electronically.” Arena v. Intuit, Inc., No. 19-cv-2546, 2021 WL 834253, at *10 (N.D. Cal. March 5, 2021) (denying preliminary approval of classwide settlement). 2. The Settlement Agreement grants Page a $5,000 service award. ¶ 9.1. The Sixth Circuit has warned that courts “should be most dubious of incentive payments when they make the class representatives whole, or … even more than whole; for in that case the class representatives have no reason to care whether the mechanisms available to unnamed class members can provide adequate relief.” In re Dry Max Pampers Litigation, 724 F.3d 713, 722 (6th Cir. 2013). Under that rejected settlement, the class representatives received a service award of $1000 per child, while absent class members received no monetary relief. Id. at 716. Here, Page would receive five times that amount, though absent class members should at least receive something: plaintiffs’ counsel estimates that “gross recovery will average $165.22,” assuming a 20% claims rate. First Motion for Preliminary Approval (DN 202) at 12. And the initial request for preliminary approval explains that some or all of Page’s proposed service award compensates her for time devoted to this litigation— not simply her recovery as a former Papa John’s employee. First Motion for Preliminary Approval at 17. These issues are not so troubling as to cause the Court to revisit its earlier holding at this juncture. And other courts have approved service fees under similar circumstances. See Daoust v. Maru Rest., LLC, No. 17-cv-13879, 2019 WL 2866490, at *6 (E.D. Mich. July 3, 2019) (approving $5,000 service award for named plaintiff against former employer who produced documents, collaborated with class counsel, and participated in mediation); Shane Group v. Blue Cross Blue Shield of Mich., 833 F. App’x 430, 431 (6th Cir. 2021) (approving $10,000 service award for plaintiffs who searched for and produced records for discovery and traveled for depositions). Despite general suspicion of service awards, therefore, this particular settlement still appears to fall “within the range of possible approval,” which is all that is required at this preliminary stage. In re High-Tech Employee Antitrust Litigation, No. 11-cv-2509, 2014 WL 3917126, at *3 (N.D. Cal. Aug, 8, 2014). But given the caselaw and considerations noted above, these issues may deserve consideration before or during the final fairness hearing. B. Rule 23(a) & (b). “Before a court may certify a class, it must ensure that the class satisfies each of Rule 23(a)’s requirements and that it falls within one of three categories permitted by Rule 23(b).” Int’l Union, United Auto., Aerospace, & Agricultural Implement Workers of America v. General Motors Corp., 497 F.3d 615, 625 (6th Cir. 2007). This Court already held that Page has likely established numerosity, adequacy of class counsel, and superiority. Opinion at 4. And commonality “is subsumed under, or superseded by, the more stringent … requirement that questions common to the class predominate over other questions.” Amchem Products, Inc. v. Windsor, 521 U.S. 591, 609 (1997). So (as indicated by the Court’s prior order) the only remaining questions are typicality, adequacy, and predominance. 1. Typicality. A class representative’s claims must be “typical of the claims … of the class.” FED. R. CIV. P. 23(a)(3).

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Bluebook (online)
in Re: Papa John's Employee and Franchisee Employee Antitrust Litigation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-papa-johns-employee-and-franchisee-employee-antitrust-litigation-kywd-2025.