Last week, the Los Angeles County Superior Court decided in Castillo, et al. v. Glenair, Inc. No. B278239, Calif. App., 2nd Dist., Div. 2, 2018 Cal. App. LEXIS 338 (“Castillo”) that, in a joint-employer arrangement, a class of workers cannot bring a lawsuit against a staffing company, settle that lawsuit, and then bring identical claims against the company where they had been placed to work.
Brothers Andrew and David Castillo, employees of a staffing company, GCA Production Services, Inc. (“GCA”), brought a wage and hour putative class action against, Glenair, Inc. (“Glenair”), a company where they had been placed to work. They characterized GCA and Glenair as joint employers and asserted that, among other things, Glenair had failed to provide required meal and rest periods, failed to pay overtime wages, and failed to pay minimum wage.
While their case against Glenair was pending, the Castillos were involved in the settlement of Gomez v. GCA Production Services, Inc. (Super. Ct. San Bernadino County, 2014, No. CIVRS1205657) (“Gomez”). The settlement in Gomez barred the settling class members from asserting certain wage and hour claims (such as those brought forth in Castillo) against GCA and its agents. The claims they asserted in Castillo were the same claims they released under the Gomez settlement for the same work done in the same period of time.
As stated in the Court’s Opinion, the Court decided that there was sufficient evidence to demonstrate that GCA had enough control over Glenair to find that Glenair was an agent of GCA, as GCA authorized Glenair to perform necessary timekeeping-related tasks for GCA employees at Glenair’s facility. Therefore, the Court found that the Gomez settlement bars the Castillos’ claims against Glenair as a matter of law, due to the Castillos’ release of these claims against agents of GCA. The Court stated that “if the Castillos were permitted to pursue their causes of action here, they would undermine the finality of the bargained-for and court-approved Gomez settlement, waste judicial resources, and potentially obtain a double recovery on their already-settled claims” (emphasis added).
COUNSEL TO MANAGEMENT:
This employer-friendly decision is exciting in that it emphasizes that settlements represent a bargained-for finality, and it explicitly notes that allowing claims against a company when the plaintiff has already settled the exact same claims with its joint employer would be wasteful and redundant. If you have any questions or concerns about your company’s wage and hour liability, please contact the experts at The Saqui Law Group.