Kent v. Tech Mahindra (Americas) Inc

CourtDistrict Court, W.D. Washington
DecidedNovember 18, 2024
Docket2:24-cv-01168
StatusUnknown

This text of Kent v. Tech Mahindra (Americas) Inc (Kent v. Tech Mahindra (Americas) Inc) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kent v. Tech Mahindra (Americas) Inc, (W.D. Wash. 2024).

Opinion

1 The Honorable Barbara J. Rothstein

5 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 6 AT SEATTLE

7 NO. 24-cv-1168-BJR STEPHEN KENT, 8 ORDER GRANTING STAY Plaintiff, 9 v. 10 TECH MAHINDRA (AMERICAS) INC., et al., 11 Defendants. 12

13 I. INTRODUCTION 14 Plaintiff, Stephen Kent, originally filed this case in King County Superior Court alleging 15 that Defendants, Tech Mahindra (Americas) Inc., Tech Mahindra Technologies Inc., and Tech 16 Mahindra Network Services International, Inc., (collectively, “Tech Mahindra”), had violated a 17 specific provision of Washington State’s Equal Pay and Opportunities Act (“EPOA”), RCW 18 49.58.110, which requires certain employers to disclose the wage scale or salary range, and a 19 general description of other compensation and benefits, in each posting for an available position. 20 Tech Mahindra removed the case to this Court on the basis of diversity jurisdiction under 28 U.S.C. 21 § 1332. Notice of Removal, ECF No. 1. Now pending before the Court is Defendant’s motion to 22 dismiss, ECF No. 12, Plaintiff’s motion to remand this case, ECF No. 14, and Defendants’ motion 23

24 ORDER GRANTING STAY 1 to stay, ECF No. 17. Having reviewed the materials1 and the relevant legal authorities, the Court 2 will grant Defendant’s motion to stay this case pending a decision by the Washington Supreme 3 Court on the definition of the term “job applicant” under the EPOA. The reasoning for the Court’s 4 decision follows. 5 II. BACKGROUND 6 On July 2, 2024, Stephen Kent applied on LinkedIn for a job opening as a Data Engineer 7 with Tech Mahindra in King County, Washington. Compl. ¶ 27; Ex.1,2 ECF No. 1-2. He alleges 8 that the posting for the job opening did not disclose the wage scale or salary range to be offered. Id. 9 ¶ 29; Ex.1. He further alleges that he was qualified for the position, and that he expected to learn 10 the rate of pay for the open position before completing the entire application. Id. ¶¶ 28, 30-31. Mr. 11 Kent alleges that he lost valuable time applying for the position and his ability to negotiate pay

12 remains adversely affected. Id. ¶¶ 35-36. Mr. Kent claims to represent more than 40 potential class 13 members who also applied for jobs with Tech Mahindra for positions that did not disclose the wage 14 scale or salary range. Id. ¶ 23. Mr. Kent filed this lawsuit against Tech Mahindra the same day, July 15 2, 2024. Id. at 10. Mr. Kent’s complaint is strikingly similar to numerous other putative class-action 16 lawsuits filed by multiple plaintiffs represented by Emery Reddy, PLLC, and subsequently removed 17 to this Court by the defendants. 18 Tech Mahindra filed a motion to dismiss on the basis that Mr. Kent is a professional plaintiff 19 who lacks statutory standing under the EPOA, and he failed to plausibly allege an EPOA claim for 20 1 Including Plaintiff’s remand motion, ECF No. 14; response in opposition, ECF No. 21; and reply, ECF No. 23. The 21 Court also reviewed Defendant’s dismissal motion, ECF No. 12, response in opposition, ECF No. 15, and reply, ECF No. 20. Defendant filed the motion to stay this case pending a decision on Judge Chun’s certified question to the 22 Washington Supreme Court in a similar case. See ECF No. 17, to which Plaintiff has filed an opposition, ECF No. 24, and Defendant has replied, ECF No. 25. 2 The Court notes that the exhibit shows a job posting on LinkedIn, although it is not evident that Mr. Kent applied 23 for the job. See Compl. Ex.1, ECF No. 1-2.

24 ORDER GRANTING STAY 1 himself or for a putative class. Mr. Kent then filed a motion to remand the case back to state court 2 on the basis that this Court lacks subject matter jurisdiction. Mr. Kent asserts that he lacks Article 3 III standing to proceed in federal court. Both motions are fully briefed. 4 On August 20, 2024, the Honorable Judge Chun certified a question in a similar case to the 5 Washington Supreme Court, asking it to interpret the term “job applicant” as used in the EPOA 6 statute. Branson v. Washington Fine Wines & Spirits, LLC, 2:24-CV-00589-JHC, 2024 WL 7 4510680, at *1 (W.D. Wash. Aug. 20, 2024), certified question accepted, 103394-0, 2024 WL 8 4471756 (Wash. Oct. 11, 2024)). On October 11, 2024, the Supreme Court of Washington issued 9 an Order accepting the federal certified question for consideration. Id. Tech Mahindra filed the 10 pending motion to stay the case pending the answer to the certified question, which Mr. Kent 11 opposes and asks the Court to first rule on his motion to remand.

12 III. LEGAL STANDARD 13 “[T]he power to stay proceedings is incidental to the power inherent in every court to 14 control the disposition of the cases on its docket with economy of time and effort for itself, for 15 counsel, and for litigants.” Landis v. N. Am. Co., 299 U.S. 428 (1936). The inherent power to stay 16 includes granting a stay of the case “pending resolution of independent proceedings which bear 17 upon the case.” Leyva v. Certified Grocers of Cal., Ltd., 593 F.2d 857, 863 (9th Cir. 1979). 18 “When considering a motion to stay, the court weighs a series of competing interests: (1) 19 the possible damage that may result from the granting of the stay; (2) the hardship or inequity 20 which a party may suffer in being required to go forward; and (3) the orderly course of justice 21 measured in terms of the simplification or complication of issues, proof, and questions of law that

22 could be expected to result from a stay.” Fed. Ins. Co. v. Holmes Weddle & Barcott PC, No. C13- 23 0926, 2014 WL 358419, at *3 (W.D. Wash. Jan. 31, 2014) (citing CMAX, Inc. v. Hall, 300 F.2d

24 ORDER GRANTING STAY 1 265, 268 (9th Cir. 1962)). A stay is appropriate when it will serve the interests of judicial economy 2 by allowing for development of factual and legal issues, and when weighing of the hardships favors 3 the granting of a stay. See, e.g., Lockyer v. Mirant Corp., 398 F.3d 1098, 1112 (9th Cir. 2005). 4 IV. DISCUSSION 5 Mr. Kent argues that the Court should first rule on his remand motion because the question 6 certified before the Washington Supreme Court relates to statutory liability and not this Court’s 7 subject-matter jurisdiction. Opp’n Stay 1-2. Mr. Kent argues that he lacks Article III standing, 8 similar to plaintiffs in other EPOA cases that this Court has remanded due to lack of standing. Id. 9 at 3; Mot. Remand 1. In those similar cases, this Court found that the plaintiffs failed to allege an 10 injury-in-fact, required for Article III standing, because they did not allege that they had applied in 11 good faith with the intent of gaining employment. See, e.g., Floyd v. Insight Global LLC, et al., 23-

12 CV-1680-BJR, 2024 WL 2133370, at *5-8 (W.D. Wash. May 10, 2024); Atkinson v. Aaron’s LLC, 13 et al., 23-CV-1742-BJR, 2024 WL 2133358, at *6-9 (W.D. Wash. May 10, 2024). The Court 14 concluded that plaintiffs must allege, at minimum, that they applied for the job with good-faith 15 intent, and as such, became personally exposed to the risk of harm caused by the statutory violation. 16 Id. 17 Mr. Kent’s complaint similarly does not include a specific allegation that he applied in good 18 faith, but it does differ from the other complaints that this Court has dismissed, because Mr. Kent 19 added an allegation that he was qualified for the position, which other complaints lacked, and may 20 inform the standing analysis. Compl. ¶ 28.

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Kent v. Tech Mahindra (Americas) Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kent-v-tech-mahindra-americas-inc-wawd-2024.