Laguna v. Coverall North America, No. 12-55479 (9th Cir. 2014)
Annotate this CasePlaintiffs filed a class action suit against Coverall, a janitorial franchising company, alleging that Coverall misclassified its California franchises as independent contractors and that Coverall breached its franchise agreements. After the parties settled, a sole objector filed an objection to the proposed settlement. The court concluded that the objector presented no evidence that the district court abused its discretion in declining further adjustment from the lodestar amount; the district court acted within its proper discretion when it found that the settlement contained significant benefits for plaintiffs beyond the cash recovery, and that the award, at about the third of the lodestar amount, was reasonable; the district court did not abuse its discretion in determining that the Churchill Vill., L.L.C. v. Gen. Elec. factors supported the conclusion that the settlement was fair, reasonable, and adequate; the district court has no obligation to make explicit monetary valuations of injunctive remedies; the district court did not abuse its discretion in approving the settlement term that objectors be available for depositions; and the district court did not abuse its discretion when it approved the settlement agreement consistent with the Class Action Fairness Act (CAFA), 28 U.S.C. 1715(b), notice requirement. Accordingly, the court affirmed the district court's approval of the proposed class action settlement under Rule 23 and the award of attorneys' fees to the attorneys of the proposed class.
Court Description: Settlement Agreement. The panel affirmed the district court’s approval of a proposed class action settlement agreement pursuant to Federal Rule of Civil Procedure 23(e), and the award of attorneys’ fees to the attorneys for the proposed class. The panel held that the district court correctly used the lodestar method in gauging the fairness of the attorneys’ fee award, correctly calculated the lodestar amount, and reasonably concluded the agreed upon award was appropriate. The panel also held that the district court did not abuse its discretion in applying the factors of Churchill Vill., L.L.C. v. Gen. Elec., 361 F.3d 566, 575 (9th Cir. 2004), when examining the fairness of the proposed settlement. The panel held that the district court had no obligation to make explicit monetary valuations of injunctive remedies. The panel further held that the district court did not abuse its discretion in approving the settlement term that objectors be available for depositions. Finally, the panel held that the district court did not abuse its discretion when it approved the settlement agreement consistent with the Class Action Fairness Act’s notice requirement described in 28 U.S.C. § 1715(b) and (d). District Judge Chen dissented because he believed that the record below is bereft of crucial information without which the district court could not fully review either the adequacy of the settlement or the reasonableness of the fee award. He would remand the case for fuller development of the record.
The court issued a subsequent related opinion or order on August 8, 2014.
The court issued a subsequent related opinion or order on November 20, 2014.
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