Ridgeway v. Walmart Inc., No. 17-15983 (9th Cir. 2020)Annotate this Case
The Ninth Circuit affirmed the district court's damages award in a class action brought by long-haul truck drivers in California, alleging that Wal-Mart violated state meal and rest break laws. The panel held that Wal-Mart raised no reversible error.
The panel rejected Wal-Mart's claim that the district court erred by failing to dismiss for lack of jurisdiction, and held that the district court correctly concluded that this case presented an Article III case or controversy because two lead plaintiffs remained in the action after the stay was lifted. The panel rejected Wal-Mart's claims that plaintiffs should not have been awarded damages for layovers, rest breaks, and inspections. The panel held that the district court correctly concluded that, under California law, time drivers spent on layovers is compensable if Wal-Mart exercised control over the drivers during those breaks; a more comprehensive review of the Wal-Mart pay manual demonstrates that it unambiguously required drivers to obtain preapproval to take a layover at home; the district court correctly determined that Wal-Mart's written policies constituted control as a matter of California law; the district court properly instructed the jury because the initial instruction on layovers and the supplemental instruction in response to a jury question—when viewed as a whole—fairly and accurately covered the issues, correctly stated the law, and were not misleading or prejudicial; the jury's factual finding, that Wal-Mart exercised control over its drivers under California law, is supported by substantial evidence; and the Federal Aviation Administration Authorization Act does not preempt California meal and break laws.
Finally, the panel affirmed the district court's judgment on damages for rest breaks and inspections; held that the district court did not err in certifying a class and allowing representative evidence as proof of classwide damages; and held that the district court did not err in finding that Wal-Mart acted in good faith and with a reasonable belief in the legality of its action.