Rittmann v. Amazon.com Inc

District Court, W.D. Washington·Decided December 2, 2024·No. 2:16-cv-01554·Unknown

Opinion

THE HONORABLE JOHN C. COUGHENOUR 1 2 3 4 5 6 UNITED STATES DISTRICT COURT 7 WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE 9 BERNADEAN RITTMANN, et al., CASE NO. C16-1554-JCC 10 Plaintiffs, ORDER 11 v. 12 AMAZON, INC., et al., 13 Defendants. 14

15 This matter comes before the Court on Plaintiffs’ renewed motion for conditional 16 certification of a collective action under the Fair Labor Standards Act (“FLSA”) (Dkt. No. 341). 17 Having thoroughly considered the briefing and the record, the Court finds oral argument 18 unnecessary and hereby GRANTS Plaintiffs’ motion as described below and for the reasons 19 explained herein. 20 I. BACKGROUND 21 The Court discussed the facts of this case in previous orders, (see, e.g., Dkt. No. 338 at 1– 22 2), and will not repeat them all here. To summarize, Plaintiffs filed a putative class action on 23 behalf of Amazon last-mile delivery drivers. (Dkt. No. 1 at 1.) They allege that Defendants 24 misclassified them as independent contractors and owe them unpaid wages and expenses. (See 25 generally id.) They originally moved for conditional certification in 2016, (Dkt. No. 20), but the 26 case was stayed until this year pending appeals in other cases. (See Dkt. Nos. 77 at 6, 298 at 1.) 1 Now, pursuant to the collective action provision of the FLSA, Plaintiffs ask the Court to 2 conditionally certify the following collective: “[A]ll individuals who worked as Amazon Flex 3 drivers since October 27, 2013.” (Dkt. No. 341 at 15.) Plaintiffs also request the Court equitably 4 toll the statute of limitations from their first motion for conditional certification. (Id.) In order to 5 facilitate notice to putative members of the collective, Plaintiffs ask the Court to (1) order 6 Defendants to produce a list of delivery drivers and their contact information within 14 days of 7 this Order; (2) direct that notice of this action be issued to the collective; and (3) establish a 180- 8 day period for opting into the action with a reminder notice halfway through the period. (Dkt. 9 No. 341 at 12–15.) Defendants dispute the method and duration of the proposed notice period if 10 the collective is conditionally certified. (Dkt. No. 352 at 36–37.) Separately, Defendants object to 11 Plaintiffs’ request for equitable tolling. (Id. at 38–41.) The Court considers the parties 12 submissions on conditional certification and the proposed notice in turn. 13 II. DISCUSSION 14 A. Legal Standard for Notice to Issue 15 The FLSA permits individuals to bring employment claims on behalf of themselves and 16 other “similarly situated” employees. 29 U.S.C. § 216(b). To facilitate a collective action, a 17 plaintiff may seek “conditional certification” at a court’s discretion. See Hoffman-La Roche Inc. 18 v. Sperling, 493 U.S. 165, 169 (1989); Campbell v. City of Los Angeles, 903 F.3d 1090, 1100–01 19 (9th Cir. 2018). Unlike Rule 23 class certification, “[t]he sole consequence of conditional 20 certification is the sending of court-approved written notice to employees . . . who in turn 21 become parties to a collective action only by filing written consent.” Genesis Healthcare Corp. 22 v. Symczyk, 569 U.S. 66, 75 (2013). For this reason, an FLSA collective does not present the 23 same due process concerns that absent and unrepresented class members do under Rule 23. 24 1 Joseph M. McLaughlin, McLaughlin on Class Actions § 2:16 (21st ed. 2024). Thus, FLSA 25 collectives of similarly situated employees are conditionally certified under a more lenient 26 standard than Rule 23 classes. See Campbell, 903 F.3d at 1112–13. 1 According to the Ninth Circuit, employees “are similarly situated [under the 2 FLSA] . . . to the extent they share a similar issue of law or fact material to the disposition of 3 their FLSA claims.” Campbell, 903 F.3d at 1117. FLSA claims frequently meet this standard by 4 alleging a violative practice or policy by a common employer, as Plaintiffs do here. See, e.g., 5 Fernandez v. Tox Corp., 677 F. Supp. 3d 1089, 1096 (C.D. Cal 2023) (collecting cases). The 6 material issues of law or fact in these cases relate to the alleged policy. See Senne v. Kan. City 7 Royals Baseball Corp., 934 F.3d 918, 949 (9th Cir. 2019). And dissimilarities between 8 employees do not defeat conditional certification. Campbell, 903 F.3d at 1114. The standard is 9 not the same as Rule 23 commonality or predominance, nor does it require a rigorous analysis of 10 whether the plaintiffs are similarly situated. See Roberts v. Sidwell Air Freight Inc., 2022 WL 11 16949565, slip op. at 4 (W.D. Wash. 2022) (rejecting the “rigorously scrutinize” standard laid 12 out in Swales v. KLLM Transp. Servs., LLC, 985 F.3d 430, 434 (5th Cir. 2021)). 13 The “similarly situated” analysis proceeds in two stages. Campbell, 903 F.3d at 1109. At 14 stage one, a court may conditionally certify the plaintiff’s proposed collective. Id. At stage two, a 15 defendant may move to decertify the collective (following notice and discovery). Id. The Court 16 here considers Plaintiffs’ stage one motion. A court assesses similarity at stage one without the 17 benefit of additional opt-in plaintiffs or discovery. Id. Thus, the analysis is more “lenient” at 18 stage one than two. Id. 19 As the Campbell court described, district courts “both within this circuit and without” 20 have reached a “loose consensus”—the standard of proof at stage one is “akin to a plausibility 21 standard,” such that the “court’s analysis is typically focused on a review of the pleadings but 22 may sometimes be supplemented by declarations or limited other evidence.” Id. at 1108–09 23 (citing Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009)). In other words, named plaintiffs must make 24 sufficient factual allegations in their complaint and submissions to support a violation by a 25 common employment policy. Villarreal v. Caremark LLC, 66 F. Supp. 3d 1184, 1189 (D. Ariz. 26 2014) (abrogated on other grounds). The standard at stage one, compared to class certification 1 under Rule 23, “is fairly lenient and typically results in certification.” Rozeboom v. Dietz & 2 Watson, Inc., 2018 WL 2266692, slip op. at 2 (W.D. Wash. 2018). 3 B. Plaintiffs’ Proposed FLSA Collective 4 Plaintiff delivery drivers claim that the members of their proposed collective are similarly 5 situated because Defendants employed them all under a common policy. (Dkt. No. 341 at 10– 6 12.) Plaintiffs’ relationship with Defendants is governed by standard Terms of Service (“TOS”). 7 (Dkt. No. 331-4 at 5–6.) While the TOS have changed somewhat over time, (see generally Dkt. 8 Nos. 248-1 to 248-7, 352 at 14), it is undisputed that two key terms have not (in any material 9 way): (1) the “Independent Contractor Relationship” that classifies Plaintiffs as contractors 10 rather than employees, (see, e.g., Dkt. No. 248-7 at 2–3), and (2) the “Service Fees” that govern 11 pay (see, e.g., Dkt. No. 248-7 at 3). (See Dkt. Nos. 352 at 13–14, 342 at 14–15). Plaintiffs allege 12 the TOS constitute a common that improperly classified them as independent contractors, denied 13 them minimum wage, and did not pay overtime. (Dkt. Nos. 341 at 10–12, 262 at 2) (citing 29 14 U.S.C. §§ 201 et seq.). 15 While Defendants do not dispute the two common terms, they point out that the TOS do 16 vary over time with respect to arbitration. (See Dkt. No.

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