Rangel v. PLS Check Cashiers of California, Inc., No. 16-56826 (9th Cir. 2018)
Annotate this CaseThe Ninth Circuit affirmed the district court's dismissal of a wage-and-hour action brought under the Fair Labor Standards Act (FLSA) based on res judicata grounds. In this case, plaintiff conceded that she was subject to a state class-action settlement that released all claims arising from the allegations on which her FLSA action was predicated. The panel applied California law and held that the FLSA action was not excepted from the ordinary operation of res judicata because the decision in the prior proceeding was final and on the merits, the present proceeding was on the same cause of action as the prior proceeding, and the parties in the present proceeding were parties to the prior proceeding.
Court Description: Labor Law. The panel affirmed the district court’s dismissal, on res judicata grounds, of a wage-and-hour action brought under the Fair Labor Standards Act. The plaintiff conceded that she was subject to a state class-action settlement that released all claims arising from the allegations on which her FLSA action was predicated. She argued that her FLSA claims nonetheless could not have been released in the settlement because the settlement was the product of an opt-out class asserting only state labor law claims, but FLSA collective actions are opt-in actions. Applying California law, the panel held that the FLSA action was not excepted from the ordinary operation of res judicata because the decision in the prior proceeding was final and on the merits, the present proceeding was on the same cause of action as the prior proceeding, and the parties in the present proceeding were parties to the prior proceeding.
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