Zabeena Maharaj v. Hertz Corp.

District Court, N.D. California·Decided March 6, 2026·No. 3:23-cv-04726·Unknown

Opinion

ZABEENA MAHARAJ, RODOLFO Case No. 23-cv-04726-JSC SCHULZ, Plaintiffs, ORDER RE: PLAINTIFFS’ MOTION FOR CLASS CERTIFICATION v. Re: Dkt. No. 62 THE HERTZ CORPORATION, Defendant.

Plaintiffs are managerial employees of Defendant, a car rental company. Plaintiffs, on behalf of a putative California class, allege Defendant misclassified them as exempt from various wage and hour laws, and thus denied them wages, overtime, meal and rest periods, and accurate wage statements, because Plaintiffs spend most of their time performing duties expected of hourly employees. (Dkt. No. 42.)1 Before the Court is Plaintiffs’ motion for class certification. (Dkt. No. 62.) Having carefully reviewed the parties’ briefing, and having had the benefit of oral argument on March 5, 2026, the Court DENIES Plaintiffs’ motion. Plaintiffs have not met their burden of showing common questions of law or fact predominate over questions affecting individual members. BACKGROUND A. Plaintiffs’ Allegations and Motion for Class Certification As relevant here, Defendant employed Plaintiffs as Operations Managers (OMs) and Customer Service Managers (CSMs). (Dkt. No. 42 ¶¶ 14-16.) “Defendant utilizes California OMs and CSMs as part of their workforce at its car rental locations. Their primary duties are waiting on customers at the vehicle rental counter, driving vehicles from one location to another, washing vehicles, handling vehicle returns, and general customer service.” (Id. ¶ 24.) “Named Plaintiff Zabeena Maharaj … was employed by Defendant from approximately August 2016 to September 2022 as an Operations Manager in Oakland, California,” and Named Plaintiff Rodolfo Schulz worked for Defendant between November 2013 and September 2021 as both a CSM and an OM. (Id. ¶¶ 14-15.) Defendant’s policy “uniformly classif[ied] OMs and CSMs as exempt from federal overtime provisions” and “from the protections of the California Labor Code.” (Id. ¶¶ 25, 28.) Despite their classification as managers, “Plaintiffs’ … primary duty was not management.” (Id. ¶ 33.) Plaintiffs “spent the vast majority of their time performing” “non-exempt duties” such as “general customer service and vehicle preparation.” (Id. ¶ 34.) And so, Defendant misclassified Plaintiffs as exempt when Plaintiffs were effectively hourly employees. As such, Plaintiffs bring nine causes of action under California’s Labor Code, unfair competition law, and Private Attorneys’ General Act. (Id. ¶¶ 38-130.) Plaintiffs move to certify the following class under Federal Rule of Civil Procedure 23(b)(3): “All persons employed by Hertz in California as exempt-classified Operations Managers (‘OMs’) at any time from June 30, 2021, through the date of class certification.” (Dkt. No. 62 at 2.) Plaintiffs also move to appoint Plaintiffs Maharaj and Schulz as class representatives and to designate Plaintiffs’ counsel as class counsel. (Id. at 8.) B. Plaintiffs’ Evidence Plaintiffs attach the deposition of Defendant’s person most knowledgeable (“PMK”), Greg Boardman, and Defendant’s discovery responses. (Dkt. No. 62-6.) Mr. Boardman is the director of human resources for southern California. (Id. at 11:8-11.) As relevant here, Defendant’s discovery responses demonstrate “[s]ince June 30, 2021, Hertz has employed 160 Operations Managers in California.” (Id. at 76.) Mr. Boardman testified as to the standardized nature of an OM’s duties. He explained corporate decision.” (Id. at 34:12-18.) An OM’s role is to “support[] all of [Defendant’s] front- end … hourly employees… essentially making sure that flow of business is happening, conducting audits throughout the day, assisting with any customer-related issues that maybe another employee is unable to handle[.]” (Id. at 20:24-21:8.) Additionally, “the primary responsibilities and the primary duties of operations managers remain constant across locations, but the emphasis might change from one location to the other and the intensity might change” based on the volume of the airport and staffing levels. (Id. at 28:20-29:18.) But across the board, due to the company’s collective bargaining agreement, OMs are “not permitted to conduct” “bargain work”; for instance, an operations manager can “assist” in conducting rentals, “but they can’t rent” cars directly to customers. (Id. at 23:10-24:16.) “[A]ll operations managers in California in Hertz locations are classified as exempt[.]” (Id. at 31:20-23.) Non-exempt positions include front-end and back-end employees like “customer service representatives, vehicle service attendants, instant-return representatives, exit gate representatives, courtesy bus drivers, and transporters.” (Id. at 32:1-13.) Mr. Boardman explained the decision to globally classify operations managers as exempt in California was “made at the corporate level,” but Mr. Boardman does not know “what factors were taken into account” in that determination. (Id. at 52:2-23.) The remainder of Plaintiffs’ evidence is declarations from putative class members. Every declarant attests, among other things, each spent over 50% of their time doing work expected to be done by hourly employees. (Dkt. No. 62-2 ¶ 3; Dkt. No. 62-3 ¶ 6; Dkt. No. 62-4 ¶ 5; Dkt. No. 62- 5 ¶ 7.) Lead Plaintiff Schulz attests he spent 80% of his time doing such work because the location was understaffed and “[a]s a matter of practice, I would receive an email … or a walkie- talkie communication[] that before the managers left home, they would need to wash [a] certain number of cars, usually between 10 and 15 cars, depending on how busy the day was.” (Dkt. No. 62-3 ¶¶ 6-8.) Another putative class member, Mr. Trice, similarly attests “upper management routinely directed” him to perform non-exempt work like washing cars. (Dkt. No. 62-4 ¶ 6.) Additionally, both lead plaintiffs explain some tasks required a process by which they (Dkt. No. 62-3 ¶¶ 7-9; Dkt. No. 62-5 ¶ 9.) Mr. Schulz attests he entered his ID number into Defendant’s system when he washed cars. (Dkt. No. 62-3 ¶¶ 7-9.) By contrast, Ms. Maharaj states she “would mostly” rent out cars “using employee ID numbers of front-end employees, which was the common practice,” so front-end employees could receive “credits,” “extra bonuses,” and “commissions.” (Dkt. No. 62-5 ¶ 9.) But it was also common practice “in [her] location” to leave a “written note with my initials” inside the car in case follow-up was needed, then dispose of the note afterwards if follow-up was not needed. (Id.) C. Defendant’s Evidence Defendant submits the depositions of Plaintiffs’ declarants, as well as declarations of Operations Managers and people who supervised or worked with Plaintiffs’ declarants. Broadly speaking, at their depositions, Plaintiffs’ declarants testified they performed many of the primary duties of OMs as reflected in job descriptions, but reaffirmed at least 50% of their time was spent performing work expected of non-exempt employees. (See generally Dkt. No. 77-1 at 70-352.)2 Unlike Plaintiffs’ declarants, the current and former Operations Managers who submitted declarations in opposition attest, among other things, they spent at most 20% of their time performing non-exempt work. (See, e.g., Dunker Dec. ¶ 13; Gravatt Dec. ¶ 7; Espiritu Dec. ¶ 8.) In broad strokes, the supervisors and coworkers weigh in on Plaintiffs’ declarants’ testimony.3 For instance, Mr. Gravatt states his “belief that if an OM is spending the majority of their time … on hourly tasks, they are not managing effectively, nor are they performing the expected duties of the job.” (Gravatt Dec. ¶ 7.) Mr. Gravatt, who worked with Lead Plaintiff Schulz, specifically recalls Mr. Schulz spent “[e]xcessive time performing hourly tasks and was not effectively managing when he did this. … I felt that Mr. Schulz was often not competently performing the core managerial functions of the OM position.” (Id. ¶ 16.) Ms. Dela Rosa, a

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Zabeena Maharaj v. Hertz Corp., (N.D. Cal. 2026).

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