Martin v. United Rentals (North America), Inc.

CourtDistrict Court, N.D. California
DecidedJune 2, 2025
Docket3:25-cv-02041
StatusUnknown

This text of Martin v. United Rentals (North America), Inc. (Martin v. United Rentals (North America), Inc.) 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
Martin v. United Rentals (North America), Inc., (N.D. Cal. 2025).

Opinion

1 2 3 UNITED STATES DISTRICT COURT 4 NORTHERN DISTRICT OF CALIFORNIA 5 6 MARIO MARTIN, Case No. 3:25-cv-02041-JSC

7 Plaintiff, ORDER RE: PLAINTIFF’S MOTION 8 v. FOR REMAND; DEFENDANT’S MOTION TO COMPEL 9 UNITED RENTALS (NORTH AMERICA), ARBITRATION INC., 10 Re: Dkt. Nos. 17, 19 Defendant.

11 12 Mario Martin filed this putative wage and hour class action in the San Francisco County 13 Superior Court against his former employer United Rentals. In the Complaint, Plaintiff alleges 14 various violations of the California Labor Code, including: (1) failure to pay wages for all hours 15 worked; (2) failure to pay overtime; (3) failure to provide meal periods; (4) failure to provide rest 16 periods; (5) failure to indemnify for employment-related expenditures; (6) failure to provide 17 complete and accurate wage statements; (7) failure to timely pay all earned wages upon 18 termination of employment; and (8) failure to pay sick wages, as well as a claim under 19 California’s Unfair Competition Law, Business and Professions Code § 17200. (Dkt. No. 1-2.1) 20 Defendant removed the action to federal court, asserting this Court has jurisdiction under 21 the Class Action Fairness Act (CAFA), 28 U.S.C. § 1332(d)(2). Plaintiff moves to remand for 22 lack of subject matter jurisdiction and Defendant has separately moved to compel arbitration. 23 (Dkt. Nos. 17, 19.) After carefully considering the parties’ briefs and the relevant legal authority, 24 the Court concludes that oral argument is unnecessary, see Civ. L.R. 7-1(b), VACATES the June 25 3, 2025 hearing, DENIES the motion to remand, GRANTS the motion to compel arbitration, and 26 STAYS the action pending arbitration. 27 1 DISCUSSION 2 I. MOTION TO REMAND 3 A. CAFA Jurisdiction 4 “CAFA gives federal district courts original jurisdiction over class actions in which the 5 class members number at least 100, at least one plaintiff is diverse in citizenship from any 6 defendant, and the aggregate amount in controversy exceeds $5 million, exclusive of interest and 7 costs.” Ibarra v. Manheim Investments, Inc., 775 F.3d 1193, 1195 (9th Cir. 2015) (citing 28 8 U.S.C. § 1332(d)). “CAFA’s provisions should be read broadly, with a strong preference that 9 interstate class actions should be heard in federal court if properly removed by any defendant.” 10 Dart Cherokee Basin Operating Co., LLC v. Owens, 574 U.S. 81, 89 (2014) (cleaned up); see also 11 Ibarra, 775 F.3d at 1197 (“Congress intended CAFA to be interpreted expansively.”). 12 Here, two out of three of CAFA’s jurisdictional requirements are uncontested. First, the 13 size of the putative class exceeds 100 people. (Dkt. No. 1-6 ¶¶ 3-4.) Second, there is minimal 14 diversity of citizenship: Plaintiff Martin is a citizen of California and United Rentals is organized 15 under the laws of Delaware and has its principal place of business in Connecticut. (Dkt. No. 1 ¶¶ 16 21-22.) The parties contest the third requirement—whether “the aggregate amount in controversy 17 exceeds $5 million, exclusive of interest and costs.” Ibarra, 775 F.3d at 1195. 18 The amount in controversy is “the maximum recovery a plaintiff could reasonably 19 recover.” Arias v. Residence Inn by Marriott, 936 F.3d 920, 927 (9th Cir. 2019). Once the 20 plaintiffs challenge the amount in controversy, the burden falls on the defendant to prove the 21 amount-in-controversy requirement is satisfied by a preponderance of the evidence. Dart 22 Cherokee, 574 U.S. at 82. The “‘amount at stake’ does not mean likely or probable liability; 23 rather, it refers to possible liability.” Jauregui v. Roadrunner Transp. Servs., Inc., 28 F.4th 989, 24 994 (9th Cir. 2022); see also id. (“the amount in controversy is supposed to be an estimate of the 25 entire potential amount at stake in the litigation”) (emphasis in original). 26 A defendant’s “mere speculation and conjecture, with unreasonable assumptions” cannot 27 establish removal jurisdiction and meet the evidentiary standard. Ibarra, 775 F.3d at 1197. An 1 hand, an assumption may be reasonable “if it is founded on the allegations of the complaint.” 2 Arias, 936 F.3d at 925; see also Perez v. Rose Hills Co., 131 F.4th 804, 808 (9th Cir. 2025) 3 (“those assumptions…can be founded on the allegations of the complaint and do not necessarily 4 need to be supported by evidence.”). The district court’s task is simply to determine if the 5 defendant’s “reasoning and underlying assumptions are reasonable.” Jauregui, 28 F.4th at 993. 6 The Complaint does not specify the amount in controversy, but alleges the aggregate 7 amount in controversy for the California sub-class is under $5 million. (Dkt. No. 1-2 at ¶ 35.) In 8 the Notice of Removal, Defendant estimates a total amount in controversy of more than $16 9 million which is based on (1) $9,874,740 for unpaid rest period premiums, (2) $6,141,719.60 for 10 waiting time penalties, and (3) attorney’s fees of between $90,000 to $199,000. (Dkt. No. 1 at ¶¶ 11 27(f), 28(e), 29(b).) 12 1. Unpaid Rest Break Premiums 13 Defendant estimates $9,874,740 for unpaid rest period premiums. Defendant calculated 14 this figure by multiplying the estimated hourly rate ($20) by the number of workweeks (164,579) 15 by the number of violations per week (3). (Dkt. No. 1 at ¶ 28(e).) Defendant based the workweek 16 number and number of violations per week on its employment records which show non-exempt 17 hourly employees in California generally work five days a week. (Dkt. No. 1-6 at ¶ 9.) Further, 18 because Plaintiff alleges the failure to provide rest breaks constitutes unfair competition under the 19 UCL, it is subject to a four-year statute of limitations so the workweeks are calculated from 20 December 13, 2020 to June 5, 2023. (Dkt. No. 1 at ¶ 28(b), (d) (quoting Dkt. No. 1-2 at ¶ 28).) 21 Plaintiff argues the $9,874,740 figure is based on the unsupported assumption that every 22 full-time class member experienced at least three rest break violations a week. Plaintiff insists the 23 Complaint only alleges class members were “periodically” and “from time to time” not provided 24 rest breaks. (Dkt. No. 1-2 at ¶¶ 12, 90-93.) The Complaint, however, also alleges Defendant had 25 a policy that prohibited employees from leaving the premises during their rest period. (Dkt. No. 1- 26 2 at ¶ 12.) Because California law requires employers allow employees to leave the work 27 premises during breaks, see Augustus v. ABM Sec. Servs., Inc., 2 Cal. 5th 257, 260 (2016), as 1 100% violation rate, although it assumed only a three times a week violation rate. 2 The Ninth Circuit’s recent ruling Perez v. Rose Hills Co., 131 F.4th 804 (9th Cir. 2025), is 3 dispositive. There, the defendant “provided a declaration from a company representative showing 4 the number of nonexempt employees it employed during the class period” and “then computed the 5 amount in controversy by making an assumption about the rate at which it was alleged to have 6 committed the various violations” “tether[ing] that assumption to the language in the complaint— 7 namely, that it had committed the alleged violations ‘at times’ and ‘throughout the statutory 8 period.’” Id. at 809.

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Bluebook (online)
Martin v. United Rentals (North America), Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/martin-v-united-rentals-north-america-inc-cand-2025.