Renati v. Wal-Mart Stores, Inc.

CourtDistrict Court, N.D. California
DecidedOctober 25, 2019
Docket3:19-cv-02525
StatusUnknown

This text of Renati v. Wal-Mart Stores, Inc. (Renati v. Wal-Mart Stores, 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
Renati v. Wal-Mart Stores, Inc., (N.D. Cal. 2019).

Opinion

1 2 3 4 5 IN THE UNITED STATES DISTRICT COURT 6 FOR THE NORTHERN DISTRICT OF CALIFORNIA 7 8 CLAUDIA RENATI, et al., Case No. 19-cv-02525-CRB

9 Plaintiffs, ORDER GRANTING MOTION TO 10 v. SEVER, DENYING IN PART AND GRANTING IN PART MOTION TO 11 WAL-MART STORES, INC., DISMISS, AND DENYING AS MOOT MOTION TO STAY DISCOVERY 12 Defendant.

13 This case is the latest iteration of a Title VII suit alleging that Wal-Mart Stores, Inc.’s 14 (“Wal-Mart”) promotion and pay policies discriminate against women. Originally brought in 15 2001 as a class action, these claims have now been heard by the Northern District of California (on 16 two previous occasions), an en banc panel of the Ninth Circuit, and the Supreme Court. Eighteen 17 members of the original nationwide class (collectively, “Plaintiffs”) have now filed suit as 18 individuals, alleging disparate treatment and impact. Wal-Mart has moved to sever, dismiss the 19 Complaint in part, and stay discovery. 20 I. BACKGROUND 21 A. Procedural History 22 This case dates back to June 2001, when current and former female Wal-Mart employees 23 brought suit on behalf of a nationwide class alleging widespread gender discrimination. Judge 24 Jenkins certified a nationwide class, which the Ninth Circuit, sitting en banc, affirmed in large 25 26 part. The Supreme Court reversed on June 20, 2011. Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 27 338, 347–48, 359–60 (2011). proposed classes to current and former female Wal-Mart employees who had been subjected to 1 2 gender discrimination within four regions largely based in California. Dukes v. Wal-Mart Stores, 3 Inc., 964 F. Supp. 2d 1115, 1117 (N.D. Cal. 2013). This Court denied certification, finding that 4 the narrowed scope did not cure the problems that had foreclosed certification of the nationwide 5 class. Id. at 1118. 6 This case followed. Plaintiffs are eighteen of the would-be class members from Dukes. 7 Compl. ¶ 5 (dkt. 1). On May 10, 2019, they filed suit in their individual capacities, alleging pay 8 and promotional discrimination on the basis of gender. See generally id. The case was initially 9 10 before Judge Koh, but was transferred to this Court because it was related to Dukes. See Order 11 Relating Cases (dkt. 32). 12 B. Factual Allegations 13 Plaintiffs, like the class in Dukes, allege Wal-Mart has violated Title VII of the Civil 14 Rights Act of 1964, 42 U.S.C. §§ 2000e, et seq., by discriminating against them on the basis of 15 gender. Compl. ¶ 1. All eighteen plaintiffs are current or former female Wal-Mart employees 16 who have worked in Wal-Mart Regions 5, 16, or 19.1 Id. ¶¶ 11–28. They assert claims for pay 17 and promotional discrimination in all three regions, based on both disparate treatment and 18 disparate impact. Id. ¶¶ 313–91. 19 The first part of the Complaint alleges that generally applicable pay and promotional 20 policies “adverse[ly] impacted[ed] female employees in all three regions.” Id. ¶¶ 98, 119. 21 Plaintiffs allege that various elements of Wal-Mart’s pay policies had an adverse impact on 22 women, “including . . . failure to require managers to base pay decisions for individual employees 23 on job related criteria[,] . . . setting pay adjustments based on the associate’s prior pay, . . . and 24 [the] 2004 pay class restructuring.” Id. ¶¶ 98. Plaintiffs also challenge a 2005 policy tying pay to 25 26

27 1 Wal-Mart’s operations are divided into thirty-five Wal-Mart Regions and five Sam’s Club 1 “credits” awarded on the basis of past experience, and a 2006 policy implementing caps on the pay 2 permitted for different classes of jobs. Id. ¶¶ 62–63. The Complaint alleges, in some detail, 3 statistically significant differences in pay for men and women in Regions 16 and 19 in 2001 and 4 2002. Id. ¶ 75. 5 Plaintiffs also allege numerous promotional policies with an adverse impact on women, 6 including the lack of formal application processes or job postings for certain management 7 positions, and the failure to “require managers to base promotion decisions . . . on job related 8 criteria.” See, e.g., id. ¶¶ 100, 101, 119. Plaintiffs allege that in each relevant Region Wal-Mart 9 promoted men and women at significantly different rates, and “had a lower percentage of female 10 managers than its largest competitors.” Id. ¶¶ 107–09. 11 The second part of the complaint details allegations of discriminatory treatment unique to 12 each plaintiff. These allegations describe specific incidents when plaintiffs were passed over for 13 promotions that went to less qualified men or learned that similarly-situated male employees made 14 more than they did. See generally id. ¶¶ 132–312. In some cases Plaintiffs were explicitly told 15 that this discriminatory treatment was motivated by gender. See, e.g., id. ¶¶ 197 (when plaintiff 16 Mavi Alulquoy inquired about promotional opportunities, managers told her women should “have 17 babies instead of lifting crates”), 271 (when Darla Harper complained about a pay disparity, her 18 manager told her “this is why you can’t be in management” and that “you females are too 19 emotional”). 20 All Plaintiffs allege they “have exhausted their administrative remedies and complied with 21 the statutory prerequisites of Title VII by timely filing charges of discrimination.” Id. ¶ 7. 22 Wal-Mart has moved to sever Plaintiffs’ claims, Mot. to Sever (dkt. 17), dismiss the 23 Complaint in part, MTD (dkt. 19), and for a stay of discovery pending resolution of the motion to 24 dismiss, Mot. for Stay (dkt 18). 25 II. LEGAL STANDARDS 26 A. Motion to Sever 27 “[J]oinder is proper if (1) the plaintiffs asserted a right to relief arising out of the same 1 transaction and occurrence and (2) some question of law or fact common to all the plaintiffs will 2 arise in the action.” Coleman v. Quaker Oats Co., 232 F.3d 1271, 1296 (9th Cir. 2000) (emphasis 3 in original); see also Fed. R. Civ. P. 20(a)(1). The requirements for joinder are “construed 4 liberally in order to promote trial convenience and . . . prevent[] multiple lawsuits.” League to 5 Save Lake Tahoe v. Tahoe Reg’l Planning Agency, 558 F.2d 914, 917 (9th Cir. 1977). Even if 6 Rule 20’s requirements are satisfied, courts must also consider whether joinder “would comport 7 with fundamental principles of fairness or would result in prejudice to either side.” Coleman, 232 8 F.3d at 1296 (internal quotation marks omitted). If plaintiffs have been misjoined, their claims 9 may be severed “as long as no substantial right will be prejudiced.” Coughlin v. Rogers, 130 F.3d 10 1348, 1351 (9th Cir. 1997); see Fed. R. Civ. P. 21. 11 B. Motion to Dismiss in Part 12 13 A complaint that fails to state a claim upon which relief may be granted must be dismissed 14 under Federal Rule of Civil Procedure 12(b)(6). A complaint fails to state a claim when it asserts 15 no cognizable legal theory or fails to allege sufficient facts to support a cognizable legal theory. 16 Conservation Force v. Salazar, 646 F.3d 1240, 1242 (9th Cir. 2011). In deciding the motion to 17 dismiss, the Court “must presume all factual allegations of the complaint to be true and draw all 18 reasonable inferences in favor of the nonmoving party.” Usher v. City of Los Angeles, 828 F.2d 19 556, 561 (9th Cir. 1987).

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Bluebook (online)
Renati v. Wal-Mart Stores, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/renati-v-wal-mart-stores-inc-cand-2019.