Platero v. United States

CourtUnited States Court of Federal Claims
DecidedMarch 18, 2026
Docket25-782
StatusPublished

This text of Platero v. United States (Platero v. United States) is published on Counsel Stack Legal Research, covering United States Court of Federal Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Platero v. United States, (uscfc 2026).

Opinion

In the United States Court of Federal Claims

BRANDON A. PLATERO and ADAM BROOKS et al.,

Plaintiffs, Nos. 25-782; 25-1245 v. Filed March 18, 2026 THE UNITED STATES,

Defendant.

OPINION AND ORDER Granting plaintiffs’ motion for class certification and denying without prejudice plaintiffs’ requests regarding the proposed notice

After the Supreme Court’s decision in Feliciano v. Department of Transportation, 605 U.S.

38 (2025), plaintiffs sued the U.S. government to recover reservist differential pay under 5 U.S.C

§ 5538 and interest under the Back Pay Act, 5 U.S.C § 5596. Plaintiffs move to certify the case as

a class action, arguing that they meet all the requirements of this court’s rules 23(a) and (b)—

numerosity, commonality and predominance, typicality, adequacy, and superiority. The govern-

ment opposes the motion. Because plaintiffs meet the requirements under this court’s rules, they

qualify for class certification, and the court will grant plaintiffs’ motion for class certification.

The court will deny without prejudice plaintiffs’ requests regarding the proposed notice

and the timing for issuing it to potential class members.

I. Background

Under federal law, civilian federal employees are entitled to a “non-reduction” in pay for

the time they serve on active duty in the military reserve or the National Guard. 5 U.S.C § 5538(a).

Employees are entitled to that reservist differential pay when they are called or ordered to service

1 “under … a provision of law referred to in [10 U.S.C § 101(a)(13)(B)]” (5 U.S.C § 5538(a)), which

includes “any other provision of law during a war or during a national emergency declared by the

President or Congress” (10 U.S.C § 101(a)(13)(B)). In April 2025, the Supreme Court held that a

federal civilian employee “called to active duty pursuant to ‘any other provision of law … during

a national emergency’ is entitled to differential pay without having to prove that his service was

substantively connected in some particular way to some particular emergency.” Feliciano, 605

U.S. at 55-56.

Plaintiffs in this case state that they are current or former government employees across

different federal agencies who have been reserve members of the armed forces or the National

Guard and have served in active-duty status during a national emergency sometime from May 6,

2019, forward. ECF No. 30 at 1 [¶2]. Plaintiffs seek to recover reservist differential pay under

5 U.S.C § 5538 and to receive interest on their unpaid wages under 5 U.S.C § 5596. Id. Plaintiffs

seek to bring this case as a class action under rules 23(a) and (b) of the Rules of the Court of

Federal Claims (RCFC) on behalf of themselves and others similarly situated, alleging that there

are “hundreds, if not thousands, of members of the Class.” Id. at 10-11 [¶¶38-39]. They allege that

there are questions of law and fact common to the members of the putative class that predominate

over any questions that may affect individual class members; the representative plaintiffs are ade-

quate, committed to pursuing this action, and willing and able to represent the proposed class; and

a class action is superior to other methods for fair and efficient adjudication and will prevent un-

duly duplicative litigation. Id. at 11-12 [¶¶40-45].

Plaintiffs argue that because they meet all the requirements of RCFC 23(a) and (b)—nu-

merosity, commonality and predominance, typicality, adequacy, and superiority—the court should

certify their class and authorize the issuance of a notice to all eligible individuals who meet the

2 following definition: “All federal employees who, at any time from May 6, 2019, through the

present, were not paid the difference between their federal civilian salary and their military pay

during their time spent in active duty during a national emergency.” ECF No. 35-1 at 6; ECF No.

30 at 10 [¶38]. The government opposes, arguing that plaintiffs have not met the requirements for

class certification and that plaintiffs’ class definition is overbroad. ECF No. 43.

II. Discussion

A. Plaintiffs satisfy all class requirements under RCFC 23

Rule 23 sets the standard for class certification in this court. Under rule 23(a), “[o]ne or

more members of a class may sue as representative parties on behalf of all members only if: (1)

the class is so numerous that joinder of all members is impracticable; (2) there are questions of law

or fact common to the class; (3) the claims or defenses of the representative parties are typical of

the claims or defenses of the class; and (4) the representative parties will fairly and adequately

protect the interests of the class.” RCFC 23(a). If all rule 23(a) factors are satisfied, rule 23(b)

provides that a class action may be maintained if “the United States has acted or refused to act on

grounds generally applicable to the class” and if “the court finds that the questions of law or fact

common to class members predominate over any questions affecting only individual members,

and that a class action is superior to other available methods for fairly and efficiently adjudicating

the controversy.” RCFC 23(b).

This court has “conveniently restated [rules 23(a) and (b) collectively] as comprising five

elements: (1) numerosity; (2) commonality; (3) typicality; (4) adequacy; and (5) superiority.”

Curry v. United States, 81 Fed. Cl. 328, 332 (2008). Plaintiffs bear the burden of showing that “the

action is maintainable under” rule 23(b). Amchem Products, Inc. v. Windsor, 521 U.S. 591, 14

(1997); see also Silver Buckle Mines, Inc. v. United States, 132 Fed. Cl. 77, 95 n.16 (2017) (“[W]ith

the notable exception that RCFC 23 allows only opt-in class action …, case law analyzing [rule

3 23 of the Federal Rules of Civil Procedure] may be used to construe RCFC 23”). To determine

whether plaintiffs have met their burden, “the Court must conduct a ‘rigorous analysis’ and thus

probe beyond the pleadings.” Oztimurlenk v. United States, 162 Fed. Cl. 658, 673 (2022) (quoting

Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338, 350 (2011)). Once that “rigorous analysis is con-

ducted, the Court has wide discretion in deciding whether the requirements of RCFC 23 have been

satisfied.” Oztimurlenk, 162 Fed. Cl. at 673 (quotation marks omitted).

1. The putative class satisfies the numerosity requirement

RCFC 23(a)(1) states that a class action is appropriate when “the class is so numerous that

joinder of all members is impracticable.” Because “[i]mpracticable does not mean impossible,” a

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Related

Amchem Products, Inc. v. Windsor
521 U.S. 591 (Supreme Court, 1997)
Wal-Mart Stores, Inc. v. Dukes
131 S. Ct. 2541 (Supreme Court, 2011)
Jones v. United States
118 Fed. Cl. 728 (Federal Claims, 2014)
Demons v. United States
119 Fed. Cl. 345 (Federal Claims, 2014)
Silver Buckle Mines, Inc. v. United States
132 Fed. Cl. 77 (Federal Claims, 2017)
Favreau v. United States
48 Fed. Cl. 774 (Federal Claims, 2000)
Barnes v. United States
68 Fed. Cl. 492 (Federal Claims, 2005)
Jaynes v. United States
69 Fed. Cl. 450 (Federal Claims, 2006)
Curry v. United States
81 Fed. Cl. 328 (Federal Claims, 2008)
King v. United States
84 Fed. Cl. 120 (Federal Claims, 2008)
Armstrong v. Davis
275 F.3d 849 (Ninth Circuit, 2001)
Gross v. United States
106 Fed. Cl. 369 (Federal Claims, 2012)
Y & J Properties, Ltd. v. United States
134 Fed. Cl. 465 (Federal Claims, 2017)
Feliciano v. Department Of Transportation
605 U.S. 38 (Supreme Court, 2025)

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