On appeal from the Santa Clara County Superior Court (California), In these consolidated class actions against appellees, the trial court entered judgment certifying a nationwide class and approving a class settlement. Appellants, who objected to the class settlement in the trial court, appealed.
Overview
Appellees, computer manufacturer, began to experience financial difficulties and ended a “lifetime” free technical support for its products, and initiated a fee-based program. Three different class actions were brought by owners of the products; the class actions were ultimately consolidated and settled. Appellants objected to the settlement, arguing that the trial court applied improper criteria in certifying the nationwide class, failed to protect the rights of absent class members, the notice was legally inadequate, the settlement did not fairly compensate the class members, and that the attorney fee award was inappropriate. Affirming, the court held that the trial court did not abuse its discretion in the certification of a nationwide class, and the class representatives met all the necessary requirements. Additionally, the applicable California law provided an adequate remedy for nationwide consumers. Moreover, the settlement represented a reasonable compromise in light of all of the facts, and notice was well within precedent and the contents of the notice were legally sufficient. Finally, the Lodestar and multiplier calculation and award of attorneys fees was proper.
Outcome
The court affirmed the litigation attorney judgment that certified the class, approved the class settlement, and awarded attorney fees.
Procedural Posture
Plaintiffs, an employee and a former employee, sought to bring a class action suit against defendant employer for alleged violations of Cal. Lab. Code §§ 226.7, 227.3, Cal. Bus. & Prof. Code §§ 17200-17210. Before the court were the employees’ applications for final approval of settlement, attorneys’ fees and costs, and additional compensation for the named plaintiffs.
Overview
The complaint alleged that the employer failed to pay (1) overtime wages; (2) administrative leave wages; and (3) accrued but unused vacation wages. In approving the settlement under Fed. R. Civ. P. 23(e), the court held that (1) the employees’ case was quite strong in certain aspects; (2) despite having significantly developed the facts, both sides faced significant uncertainty because the claims encompassed unsettled legal issues, and the complexity and duration of further litigation was likely to be considerable; (3) it was not clear that the classes would remain intact if trial proceeded; (4) the amount offered in settlement was appropriate as the employees were ensured compensation for their injuries and the rate of compensation was fair and reasonable; (5) the advanced stage of the proceedings suggested that the parties had carefully investigated the claims before reaching resolution; (6) the proposed fee calculation, which was 25 percent of the amount recovered, was reasonable; (7) the employees’ attorneys were entitled to recover costs; and (8) the class representatives were entitled to an enhancement award based on their assistance in the case.
Outcome
The court granted final approval of the settlement, attorneys’ fees and costs, and additional compensation to the class representatives.