Ibarra v. Manheim Investments

In order for a class action lawsuit to abide by the Class Action Fairness Act, definitive evidence of the amount in controversy must be submitted to the court for review.

In this action, Jose Ibarra, filed a putative class action against his former employer, which alleged that the employer violated the California Labor Code for failure to pay minimum wage and overtime to its employees. The complaint also alleged that the employer neglected to provide meal and rest periods for the workers and failed to pay their wages in a timely manner upon termination. The defendant, Manheim, removed this action to federal court, but the case was eventually remanded back to district court. Ibarra, who represented the class, stated in his initial claim that “the aggregate claims of the individual class members do not exceed the $5,000,000 jurisdictional threshold for federal court under the Class Action Fairness Act.” On remand, the district court reviewed the parties’ briefs and other evidence, and concluded that: “Manheim had not satisfied its burden of proving that the amount in controversy exceeded $5 million, because Manheim did ‘not provide a basis in the complaint or in evidence for [its] assumption that plaintiffs were never provided breaks.’” Manheim subsequently appealed the decision. The Ninth Circuit held that Manheim bore the burden to show that the amount in question, in this case $5,000,000, “relied on reasonable assumptions.” The panel based this conclusion on the fact that the complaint “did not allege that Manheim universally, on each and every shift, violated labor laws by not giving rest and meal breaks.” Additionally, the panel held that if the damages were mere assumptions, then there needed to be some concrete ground on which the assumptions were founded upon. The panel concluded that the assumptions were not fully supported and that more evidence needed to be presented to meet the burden of proof. VACATED and REMANDED.