Joh v. American Income Life Insurance Company

District Court, N.D. California·Decided January 7, 2021·No. 3:18-cv-06364·Unknown

Opinion

DAVID JOH, et al., Case No. 18-cv-06364-TSH

Plaintiffs, ORDER RE: MOTION FOR FINAL v. APPROVAL OF REVISED CLASS ACTION SETTLEMENT AND AMERICAN INCOME LIFE INSURANCE REQUEST FOR ATTORNEYS' FEES, COMPANY, COSTS, AND SERVICE AWARDS Defendant. Re: Dkt. No. 75 Before the Court are Plaintiffs’ Motion for Final Approval of Revised Class Settlement and Request for Attorneys’ Fees, Costs, and Service Awards. ECF No. 75. Having reviewed the Settlement Agreement and the Plaintiffs’ moving papers, and after a hearing on the Motions, the Court GRANTS them both. A. Facts Plaintiffs in this action are former insurance salesperson trainees or agents of American Life Insurance Company (“AIL”), who trained and worked at locations in California. Plaintiffs allege that as prospective AIL agents, trainees would undergo training that lasted one week or more without earning a commission or otherwise being paid. Sec. Am. Compl. (“SAC”) ¶ 18, ECF No. 30. They allege that AIG promised prospective agents salaried positions, but then hired them as commission-only employees, and failed to pay or reimburse them while they worked as sales agents. Id. ¶ 42. They allege that as trainees and agents they were not paid a minimum wage or overtime pay, did not receive proper meal and rest breaks, and had to pay their own work- related expenses. Id. ¶ 20. They also allege that agents were subject to “chargebacks,” meaning collected back commissions from the agents earned wages. Id. ¶ 28. Plaintiffs seek to represent a class of “[a]ll individuals who trained to become and/or worked as sales agents in California for Defendant during the last four years prior to the filing of the original Complaint.” Id. ¶¶ 32-33. Plaintiffs assert the following: unlawful, unfair, and fraudulent business practices in violation of California Business and Professions Code §§ 17200, et seq.; failure to pay California overtime compensation in violation of California Labor Code §§ 510 and 1194, and Industrial Welfare Commission (“IWC”) Wage Order No. 4; failure to pay minimum wages in violation of Labor Code §§ 1194 and 1197, and IWC Wage Order No. 4; failure to provide meal periods in violation of Labor Code §§ 226.7 and 512, and IWC Wage Order No. 4; failure to provide rest periods in violation of Labor Code § 226.7 and IWC Wage Order No. 4; waiting time penalties pursuant to Labor Code §§ 202 and 203; failure to furnish accurate wage statements in violation of Labor Code § 226 and IWC Wage Order No. 4; failure to reimburse expenses and illegal chargebacks in violation of Labor Code §§ 221 and 2802, and IWC Wage Order No. 4; failure to pay wages/commissions in violation of Labor Code §§ 221, 203 and 204; declaratory relief pursuant to 28 U.S.C. § 2201; and civil penalties pursuant to the California Private Attorneys General Act (“PAGA”), Labor Code §§ 2698, et seq. B. Rejection of the First Settlement Agreement On April 16, 2019, counsel for Plaintiffs and AIL participated in an all-day mediation with an experienced mediator, after which the mediator proposed an agreement which the Parties accepted (the “First SA”). On August 1, 2019, Plaintiffs filed a Motion for Preliminary Approval of Class Action Settlement, ECF No. 39, which the Court granted on August 16, 2019, ECF No. 41. On November 5, 2019, a number of class members filed an objection to approval of the agreement. ECF No. 44. The Court held a final approval hearing on January 9, 2020, after which the Court denied final approval. In its order denying final approval, ECF No. 53 (the “Order”), the Court found the prerequisites of Federal Rule of Civil Procedure 23(a) and (b) had been met in that: the numerosity requirement had been met; there were questions of law or fact common to the Class; Plaintiffs Class; and the questions of law and fact common to the Class predominated over questions affecting only individual Class members. Order at 5-8. Additionally, Plaintiffs had met the notice requirements of Rule 23(e)(1). Id. at 8-9; see Fed. R. Civ. P. 23(e)(1). Moving to Rule 23(e)(2), the Court found that Plaintiffs and their counsel (“Counsel”) had adequately represented the Class and had negotiated the settlement in arms-length negotiations, aided by an experienced mediator who had proposed the agreement which the Parties accepted. Order at 9-13; see Fed. R. Civ. P. 23(e)(2). And the Court found the adequacy of the relief satisfied Rule 23(e)(2)(C). However, things hit a snag when the Court examined the objectors’ arguments as to the equitable treatment of class members. Rule 23(e)(2)(D) directs that, “[i]f the proposal would bind class members, the court may approve it only . . . on finding that . . . the proposal treats class members equitably relative to each other.” Fed. R. Civ. P. 23(e)(2)(D). Here, the First SA had a problem. The issue was with how the settlement value would be distributed under the agreement: under California law waiting time penalties accrue only once per employee (in this case, trainee or agent), but the First SA would distribute all of the settlement value pro rata based on the number of workweeks an employee worked, and agent workweeks were far more numerous than trainee workweeks. As a result, even though the Parties estimated that roughly 50% of maximum total liability of Plaintiffs’ claims were for California waiting time penalties and even though trainees made up 25% of those claims, trainees would receive only roughly 2% of the settlement value attributable to the waiting-time claims. In short, agent workweeks would wash out trainees’ claims to their portion of the settlement value attributable to waiting time claims. See Order at 14- 18. Accordingly, the Court found the First SA could not satisfy Rule 23(e)(2)(D). Order at 17-18. After the Court’s initial rejection of the First SA, Plaintiffs filed a Renewed Motion for Final Settlement Approval which included additional briefing on the issue of waiting-time penalties. ECF No. 60. The objector’s filed an opposition to that motion, ECF No. 61, and the Court denied it on April 15, 2020, ECF No. 65. Following that denial, the Parties met and conferred to resolve the issues in the First SA, and they finalized the terms of a revised settlement, the agreement currently before the Court (the “Settlement,” or “Revised SA”). Plaintiffs C. Key Points of the Revised Agreement The Revised SA, if approved, would dispose of all claims in this action, as well as in two related cases: Hamilton v. American Income Life Insurance Co., Case No. 3:18-cv-07535-KAW (N.D. Cal.), which claims, parties, and counsel are incorporated into the operative complaint in this case, and Golz v. American Income Life Insurance Co., 2:18-cv-09879 (C.D. Cal.)1. The Settlement Class comprises:

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