Marcie Hamilton v. JUUL Labs, Inc.

District Court, N.D. California·Decided November 16, 2021·No. 3:20-cv-03710·Unknown

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 MARCIE HAMILTON, Case No. 20-cv-03710-EMC

8 Plaintiff, ORDER GRANTING PLAINTIFF’S 9 v. MOTIONS FOR PAGA SETTLEMENT APPROVAL AND ATTORNEYS’ FEES 10 JUUL LABS, INC., Docket Nos. 80-81 11 Defendant.

12 13 14 I. INTRODUCTION 15 Plaintiff Marcie Hamilton and Private Attorneys General Act (“PAGA”) Representative 16 Jim Isaacson (“Plaintiff” for simplicity) filed this lawsuit against Hamilton’s former employer, 17 Defendant Juul Labs, Inc. (“Juul”), seeking civil penalties and injunctive relief related to alleged 18 policies, separation agreements and suppression of the whistleblowing and political activities of its 19 employees in violation of California law. Docket No. 32 (“FAC”). 20 The parties indicate that they have agreed to resolve Plaintiff’s PAGA claims through 21 monetary penalties and programmatic relief. Docket No. 80. Now pending are Plaintiff’s 22 unopposed motions for approval of the PAGA settlement, Docket No. 80 (“Settlement Motion”), 23 and for attorneys’ fees, Docket No. 81 (“Fees Motion”). 24 For the following reasons, the Court GRANTS Plaintiff’s motion to approve settlement, 25 and Plaintiff’s motion for fees and awards, subject to the modifications explained below. 26 II. BACKGROUND 27 A. Legal Basis for Plaintiff’s PAGA Claims 1 standard an employee anti-gag rule.” Doe v. Google Inc., 54 Cal.App.5th 948, 961 (2020). 2 For example, California law protects whistleblowers. Labor Code § 1102.5(a) makes it 3 unlawful for an employer to adopt or enforce a policy or rule that prevents employees from 4 disclosing information about reasonably suspected violations of the law to persons with the power 5 to address the problem, e.g., government agencies or another employee who has the authority to 6 investigate, discover, or correct the legal violation. Doe, 54 Cal.App.5th at 958. Government 7 Code § 12964.5(a) prohibits employers from requiring employees to sign certain non- 8 disparagement agreements or other documents that purport to deny them the right to disclose 9 information to anyone, including the press, about any “unlawful or potentially unlawful conduct.” 10 California law also protects a broad array of employee speech and activity unrelated to 11 whistleblowing. Labor Code § 96(k) prohibits employer retaliation for “’lawful conduct occurring 12 during nonworking hours away from the employer’s premises,’ so employers do not seek to 13 control the non-work aspects of their employees’ lives.” Doe, 54 Cal.App.5th at 958 (citations 14 omitted). Labor Code §§ 232, 232.5, and 1197.5(k) generally outlaw employer prohibitions on the 15 disclosure or discussion of wages and working conditions. 16 As the Court previously stated in this litigation, “Labor Code §§ 1101 and 1102 are 17 ‘designed to protect the fundamental right of employees in general to engage in political activity 18 without interference by their employers.’” Docket No. 42 at 21). And California Business & 19 Professions Code § 16600 outlaws contracts in restraint of trade, rendering overbroad or 20 oppressive non-disclosure agreements illegal. Brown v. TGS Management Co., LLC, 57 21 Cal.App.5th 303, 318-319 (2020). 22 California’s anti-gag rule for employees is not absolute. Labor Code § 232.5(d) states that 23 the rule prohibiting employers from requiring employees to refrain from disclosing information 24 about their working conditions “is not intended to permit an employee to disclose proprietary 25 information, trade secret information, or information that is otherwise subject to a legal privilege 26 without the consent of his or her employer.” 27 B. Plaintiff’s PAGA Claims 1 activity, and the disclosure of information beyond the limited categories of information protected 2 by law, and, therefore, violate California’s anti-gag rule. Plaintiff brought five PAGA claims (four 3 of which survived Juul’s motions to dismiss, see Docket No. 42) on behalf of Juul employees and 4 former employees challenging the following aspects of Juul’s policies and practices: 5 1. Non-Disclosure and Non-Disparagement Agreements 6 As an express condition of their employment at Juul, Ms. Hamilton and Mr. Isaacson were 7 required to sign the “Proprietary Information and Invention Assignment Agreement” (“NDA”). 8 FAC ¶ 28. Their offer letters stated the following: “this offer, and employment pursuant to this 9 offer, is conditioned upon . . . [y]our signed agreement to, and ongoing compliance with, the terms 10 of the enclosed [NDA],” and included a disclaimer that the offer letter is governed by California 11 law. Id. Plaintiff alleges that Juul has a policy of requiring all of its employees to sign this offer 12 letter (or one that is substantially similar). Id. The NDA specifically states that its employees 13 “shall at all times during the term of [their] employment with the Company and thereafter, hold in 14 strictest confidence, and not use . . . or disclose to any person, firm, or corporation, without written 15 authorization from the Company’s Board of Directors (the ‘Board’), any Confidential Information 16 of the Company.” FAC ¶ 29 (citing NDA, Docket No. 32, Ex. A, § 4.1 (“Company 17 Information”)). Plaintiffs alleges that “Confidential Information” is defined by the NDA to mean 18 essentially everything related to Juul (e.g., information about Juul’s customers, products, and 19 markets, as well as catch-all terms such as “other business information of the Company” and 20 “information disclosed by the Company to Employee and information developed or learned by 21 Employee during the course of employment with Company”). Id. (citing NDA, Docket No. 32, 22 Ex. A, § 4.1 (“Company Information”)). 23 The NDA also contains a non-disparagement provision, which prohibits employees from 24 disclosing “all information of which the unauthorized disclosure could be detrimental to the 25 interests of the Company, whether or not such information is identified as Confidential 26 Information.” FAC ¶ 30 (emphasis in original). Further, the NDA creates a presumption of 27 confidentiality, stating “Employee agrees that Employee bears the burden of proving that given 1 The NDA contains a direct nexus to the Termination Certificate discussed below because it 2 states that “[i]n the event of the termination of the Employee’s employment, Employee hereby 3 covenants and agrees to sign and deliver the ‘Termination Certificate’ attached hereto as Exhibit 4 C.” FAC ¶ 32. Plaintiff alleges it has no temporal or geographic limitation (i.e., it lasts forever 5 and applies whether an employee is on or off Juul’s premises), and it contains a provision 6 subjecting it to California law. FAC ¶¶ 34, 35. 7 2. Termination Certificate 8 On March 15, 2019, Ms. Hamilton was informed that her employment at Juul had been 9 terminated, and Juul required her to sign the “Termination Certificate” that all employees must 10 sign as a condition of employment. FAC ¶ 38. The Certificate requires employees to verify that 11 they have complied with the terms of the NDA, and further states:

12 [i]n compliance with the [NDA], I will preserve as confidential all trade secrets, confidential knowledge, data, or other proprietary 13 information, relating to products, processes, know-how, designs, formula, developmental or experimental work, computer programs, 14 data bases, other original works of authorship, customer lists, business plans, financial information or other subject matter 15 pertaining to any business of the Company or any of its employees, clients, consultants, or licensees. 16 17 FAC ¶ 38 (emphasis in original). Ms. Hamilton signed the Termination Certificate in compliance 18 with her contractual obligations, and she alleges that other Juul employees have also been required 19 to sign a standard Termination Certificate when leaving employment at Juul. FAC ¶ 39. 20 3.

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Marcie Hamilton v. JUUL Labs, Inc., (N.D. Cal. 2021).

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