Roderick Magadia v. Wal-Mart Associates


FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT RODERICK MAGADIA, individually No. 19-16184 and on behalf of all those similarly situated, D.C. No. Plaintiff-Appellee, 5:17-cv-00062- LHK v. WAL-MART ASSOCIATES, INC., a OPINION Delaware corporation; WALMART INC., a Delaware corporation, Defendants-Appellants. Appeal from the United States District Court for the Northern District of California Lucy H. Koh, District Judge, Presiding Argued and Submitted November 19, 2020 Pasadena, California Filed May 28, 2021 Before: Consuelo M. Callahan and Patrick J. Bumatay, Circuit Judges, and Gregory A. Presnell, * District Judge. Opinion by Judge Bumatay * The Honorable Gregory A. Presnell, United States District Judge for the Middle District of Florida, sitting by designation. 2 MAGADIA V. WAL-MART ASSOCIATES SUMMARY ** Article III Standing / California Labor Law In a class action suit brought by Roderick Magadia, a former Walmart employee, alleging violations of California Labor Code’s meal-break and wage-statement requirements, the panel: (1) vacated the district court’s judgment and award of damages on a Cal. Labor Code § 226.7 claim for meal-break violations and remanded with instructions to further remand the claim to state court; and (2) reversed the judgment and award of damages on two Cal. Labor Code § 226(a) claims for wage-statement violations and remanded with instructions to enter judgment for Walmart. The panel held that Magadia lacked Article III standing to bring a California Private Attorney General Act (“PAGA”) claim for Walmart’s meal-break violations since he himself did not suffer injury. Specifically, the panel noted that qui tam actions are a well-established exception to the traditional Article III analysis, but held that PAGA’s features diverged from Vermont Agency of Nat. Res. V. U.S. ex rel. Stevens, 529 U.S. 765 (2000)’s assignment theory of qui tam injury. The panel also held that PAGA’s features departed from the traditional criteria of qui tam statutes. The panel next considered whether Magadia had standing to bring his two wage-statement claims under Cal. Labor Code § 226(a), which requires employers to accurately furnish certain itemized information on its ** This summary constitutes no part of the opinion of the court. It has been prepared by court staff for the convenience of the reader. MAGADIA V. WAL-MART ASSOCIATES 3 employees’ wage statements. The panel held that a violation of § 226(a) created a cognizable Article III injury here. To determine whether the violation of a statute constituted a concrete harm, the panel conducted a two-part inquiry. First, the panel held that § 226(a) protected employees’ concrete interest in receiving accurate information about their wages in their pay statements; and Walmart’s failure to disclose statutorily required information on Magadia’s wage documents, if true, violated a “concrete interest.” Second, Magadia sufficiently alleged that Walmart’s § 226(a) violation – depriving him of accurate itemized wage statements – presented a material risk of harm to his interest in the statutorily guaranteed information. The panel also concluded that other class members who could establish § 226(a) injuries had standing to collect damages. Finally, the panel considered the …

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