Decision: In Martinez et al. v. Joe’s Crab Shack, plaintiff filed a complaint seeking to represent a group of salaried managerial employees whom he alleged were entitled to overtime. The trial court had denied plaintiff’s motion for class certification on the ground that the court would have been required to make individual determinations concerning whether each manager spent more than 50 percent of his or her time performing nonexempt tasks. The Court of Appeal disagreed, however, ruling that “class-wide relief remains the preferred method of resolving wage and hour claims, even those in which the facts appear to present difficult issues of proof.” The appellate court relied primarily onSav-on Drug Stores, Inc. v. Superior Court, 34 Cal.4th 319 (2004) in admonishing the trial court to focus its analysis “on the policies and practices of the employer and the effect those policies and practices have on the putative class,” rather than rely on the individual issues presented by different managers.
Impact: This case is one of several recent California Court of Appeal decisions to reverse a trial court’s denial of class certification and direct the trial court not to deny class certification based on varying individual class member experiences. Rather, the appropriate focus for the certification decision should be on the existence of a policy. This case also serves as a valuable reminder to employers to review their policies to ensure that they are compliant, whether with respect to exempt/nonexempt classifications, meal periods, rest periods or the like.