Roreste Refuerzo, et al. v. Southwest Airlines Co.

CourtDistrict Court, N.D. California
DecidedMay 18, 2026
Docket3:22-cv-00868
StatusUnknown

This text of Roreste Refuerzo, et al. v. Southwest Airlines Co. (Roreste Refuerzo, et al. v. Southwest Airlines Co.) 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
Roreste Refuerzo, et al. v. Southwest Airlines Co., (N.D. Cal. 2026).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 RORESTE REFUERZO, et al., Case No. 22-cv-00868-JSC

8 Plaintiffs, ORDER RE: DEFENDANT’S MOTION 9 v. FOR DECERTIFICATION

10 SOUTHWEST AIRLINES CO., Re: Dkt. No. 174 Defendant. 11

12 Plaintiffs, on behalf of themselves and three certified classes, allege Defendant violated the 13 Family and Medical Leave Act (“FMLA”) and California’s Family Rights Act (“CFRA”) by 14 deeming employees ineligible for a reduction in disciplinary points if they used protected leave. 15 Before the Court is Defendant’s motion to decertify all three classes. (Dkt. Nos. 174.)1 Having 16 carefully reviewed the parties’ written submissions, and having had the benefit of oral argument 17 on May 12, 2026, the Court denies decertification of the (b)(2) classes without prejudice, and 18 denies decertification of the (b)(3) class, but grants Plaintiffs leave to file a motion to substitute a 19 new or additional (b)(2) class representative, and grants Defendant leave to file a motion for 20 partial summary judgment to exclude certain class members. 21 BACKGROUND 22 A. The Second Amended Complaint and Certified Classes 23 Plaintiffs’ Second Amended Complaint (“SAC”) alleges five class-based causes of action: 24 (1) “Interference in Violation of the [Family and Medical Leave Act (‘FMLA’)],” 29 U.S.C. § 25 2515(a)(1); (2) “Discrimination and Retaliation in Violation of the FMLA,” 29 U.S.C §§ 26 27 1 2615(a)(1) and (2); (3) “Discrimination and Retaliation in Violation of [ California’s Family 2 Rights Act [‘CFRA’],” Cal. Gov. Code § 12945.2(1); (4) Wrongful termination; and (5) Unfair 3 Competition. (Dkt. No. 84 ¶¶ 59-89.) The first two causes of action are brought on behalf of 4 nationwide classes, and the remaining three are brought on behalf of California sub-classes. (Id.) 5 The Court previously denied Defendant’s motion to dismiss the original complaint. (Dkt. No. 25.) 6 The Court granted Plaintiffs’ motion for class certification, in part, certifying three classes. 7 (Dkt. No. 106.) The Court’s order states:

8 Plaintiffs’ claims for FMLA interference, wrongful termination, and unfair competition are certified as to the following classes: 9 The “(b)(2) Nationwide Injunctive Relief Class” 10 All Southwest flight attendants based in the United States since March 1, 2019 to present who exercised their rights to family and medical 11 leave and consequently lost access to disciplinary points reduction.

12 The “(b)(2) California Subclass” All Southwest flight attendants based in California since March 1, 13 2019 to present who exercised their rights to family and medical leave and consequently lost access to disciplinary points reduction. 14 The “(b)(3) Nationwide Damages Class” 15 All Southwest flight attendants based in the United States since March 1, 2019 to present who exercised their rights to family and medical 16 leave and consequently lost access to a disciplinary points reduction and were subsequently terminated for an accumulation of disciplinary 17 points. 18 (Dkt. No. 106 at 19.) The Court appointed Plaintiff Cashin as the class representative for each 19 (b)(2) Nationwide Injunctive Relief Class and (b)(2) California Subclass and Plaintiff Refuerzo as 20 the class representative of the (b)(3) Nationwide Damages Class. (Id. at 4, 14, 19.) 21 B. Defendant’s Point-Based Disciplinary System for Attendance 22 The Class Certification Order discusses Defendant’s point-based disciplinary system for 23 attendance. The parties do not dispute how flight attendants accumulate points and the four point- 24 reduction policies at issue here, so the Court reincorporates the prior Order’s discussion of 25 Southwest’s policy. (Id. at 1-3.) In short, Plaintiffs assert Defendant uses a point system to track 26 employees’ attendance at work shifts, where each infraction adds points to the employee’s record 27 and employees are terminated once they accumulate 12 points. Employees receive point 1 quarter. Employees are not eligible for any point reductions if they use FMLA leave, which 2 Plaintiffs assert unlawfully interferes with employees’ use of FMLA leave. 3 DISCUSSION 4 Federal Rules of Civil Procedure 23(c)(1)(c) provides “[a]n order that grants or denies 5 class certification may be altered or amended before final judgment.” As judgment has not been 6 entered, Defendant seeks decertification of all three classes on the grounds (1) Plaintiffs have not 7 established all class members’ Article III standing, and (2) Plaintiffs have not satisfied the Rule 8 23(a) and Rules 23(b)(2) and (b)(3) requirements. 9 A. The (b)(3) Class 10 1. Article III Standing 11 For a class to be certified, only one named plaintiff must demonstrate Article III standing. 12 DZ Reserve v. Meta Platforms, Inc., 96 F.4th 1223, 1239 (9th Cir. 2024). If at least one named 13 plaintiff meets the requirements, “the standing inquiry is concluded and the court proceeds to” the 14 Rule 23 analysis. Melendres v. Arpaio, 784 F.3d 1254, 1262 (9th Cir. 2015). Defendant asserts 15 the (b)(3) class should be decertified because “many” class members do not have Article III 16 standing. (Dkt. No. 174 at 15-16.) Specifically, Defendant argues many class members did not 17 suffer any injury in fact, two class members did not suffer any discernable loss, one class member 18 released her claims, and other class members were not deterred from taking FMLA leave. But 19 Plaintiff Refuerzo is the (b)(3) class representative, and Defendant does not challenge his standing. 20 As a result, “the standing inquiry is concluded,” Melendres, 784 F.3d at 1262, and the Court 21 denies Defendant’s motion as to this basis. 22 On summary judgment, in contrast to class certification, Plaintiffs must adduce evidence 23 sufficient to support a finding class members have standing. See Healy v. Milliman, Inc., 164 F.4th 24 701, 708 (9th Cir. 2026) (holding Trans Union “compels unnamed class members to demonstrate 25 evidence of standing here— after class certification but prior to trial at summary judgment”). But 26 Defendant has not filed a summary judgment motion, which would require Plaintiffs to adduce 27 facts as to unnamed class members’ standing. Instead, Defendant filed a de-certification motion, 1 standing. DZ Reserve, 96 F.4th at 1239; see also Healy, 164 F.4th at 708 (noting DZ Reserve 2 “addressed the standing inquiry at the time of class certification, not afterwards at summary 3 judgment”). And Plaintiff Refuerzo’s standing is not challenged, meaning “the standing inquiry is 4 concluded and the Court proceeds to” the Rule 23 analysis. Melendres, 784 F.3d at 1262. 5 Defendant’s reliance on Behar v. Northrop Grumman Corp., No. 2:21-CV-03946-HDV- 6 SK, 2026 WL 184300 (C.D. Cal. Jan. 20, 2026), as “plainly appl[ying] Healy in ruling on 7 defendant’s motion for decertification,” (Dkt. No. 192 at 7) is misplaced.

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Roreste Refuerzo, et al. v. Southwest Airlines Co., Counsel Stack Legal Research, https://law.counselstack.com/opinion/roreste-refuerzo-et-al-v-southwest-airlines-co-cand-2026.