Judge: David S. Cunningham, Case: JCCP5261, Date: 2023-01-04 Tentative Ruling



Case Number: JCCP5261    Hearing Date: January 4, 2023    Dept: 11

Petition for Coordination Re: TRR Wage and Hour Cases (JCCP 5261)

 

Date:                                                               1-4-23 

 

Time:                                                              2:30 pm 

 

Moving Party:                                         The RealReal, Inc. (“Petitioner” or “TRR”) 

 

Opposing Party:                                Jennifer Leighton (“Leighton”) and Stephanie Dougal (“Dougal”) (jointly “Plaintiffs”)

 

Department:                                               11                                       

 

Judge:                                                         David S. Cunningham III 

________________________________________________________________________ 

 

TENTATIVE RULING 

 

Petitioner’s petition for coordination is denied.

 

Petitioner’s stay request is denied. 

 

BACKGROUND 
 

Petitioner submitted a petition to the Chairperson of the Judicial Council for pretrial coordination of two cases (the “Included Actions”): 

 

* Leighton v. The RealReal, Inc., Case No. 21STCV11208 (Los Angeles Superior Court); and

 

* Dougal v. The RealReal, Inc., Case No. CGC22600390 (San Francisco Superior Court). 

 

The Included Actions are representative “wage and hour” actions under the Private Attorneys General Act (“PAGA”).  Petitioner contends the cases involve “overlapping groups of allegedly aggrieved [TRR] employees working in sales and allegedly misclassified as exempt” and “cover overlapping relevant time periods.”  (Petitioner’s Brief, p. 4.) 

 

The Chief Justice and Chair of the Judicial Council issued an order assigning this Court to sit as the coordination motion judge to determine whether the Included Actions are complex and, if so, whether coordination is appropriate.   

 

DISCUSSION 

 

I.         Complex Determination 

 

Only “complex” cases may be coordinated.  (Weil & Brown, Cal. Prac. Guide: Civ. Proc. Before Trial (The Rutter Group 2021) ¶ 12:374.5.)  A “complex” case requires “exceptional judicial management to avoid placing unnecessary burdens on the court or the litigants and to expedite the case, keep costs reasonable, and promote effective decision making by the court, the parties, and counsel.” (Cal. Rules of Court, rule 3.400(a).)   

 

In deciding whether an action is a complex case under (a), the Court must consider, among other things, whether the action is likely to involve: 

 

(1) Numerous pretrial motions raising difficult or novel legal issues that will be time-consuming to resolve; 

 

(2) Management of a large number of witnesses or a substantial amount of documentary evidence; 

 

(3) Management of a large number of separately represented parties; 

 

(4) Coordination with related actions pending in one or more courts in other counties, states, or countries, or in a federal court; or 

 

(5) Substantial postjudgment judicial supervision. 

 

(Id. at rule 3.400(b).) 

 

[A]n action is provisionally a complex case if it involves one or more of the following types of claims: 

 

(1) Antitrust or trade regulation claims; 

 

(2) Construction defect claims involving many parties or structures; 

 

(3) Securities claims or investment losses involving many parties; 

 

(4) Environmental or toxic tort claims involving many parties; 

 

(5) Claims involving mass torts; 

 

(6) Claims involving class actions; or 

 

(7) Insurance coverage claims arising out of any of the claims listed in (c)(1) through (c)(6). 

 

(Id. at rule 3.400(c).) 

 

Leighton has already been found to be not complex.  (See 4/7/21 Minute Order, p. 1.)  It is assigned to a non-complex courtroom.  (See 4/13/21 Minute Order, p. 1.) 

 

Dougal was deemed complex on 8/1/22, but it was a class action at that time.  (See Orr Decl., ¶ 15.)  Since then, the trial court has compelled arbitration of Dougal’s individual claims, dismissed the class claims, and stayed the PAGA representative claim pending the arbitration’s completion.  (See id. at ¶¶ 16-19.) 

 

Under these circumstances, the Court finds that the Included Actions, which are PAGA-only cases, are not complex, and the petition should be denied. 

 

II.        Code of Civil Procedure Section 404.1 

 

Section 404.1 states that a petition for coordination should be granted if doing so will “promote the ends of justice,” taking into account the following seven factors:  

 

[W]hether the common question of fact or law is predominating and significant to the litigation; the convenience of parties, witnesses and counsel; the relative development of the actions and the work product of counsel; the efficient utilization of judicial facilities and manpower; the calendar of the courts; the disadvantages of duplicative and inconsistent rulings, orders, or judgments; and the likelihood of settlement of the actions without further litigation should coordination be denied. 

 

(Code Civ. Proc. § 404.1.) 

 

A.        Predominating Common Questions 

 

This factor favors denial.  Leighton alleges two unique Labor Code violations (see Petitioner’s Brief, p. 13), Dougal alleges one unique Labor Code violation and includes a broader scope of aggrieved employees (see id. at pp. 5, 8-9, 14), the limitations/recovery periods are different (in Leighton, the pre-suit PAGA notice was submitted on 1/6/21 (see Orr Decl., Ex. 1, ¶ 19), in Dougal, it was submitted on 5/10/22 (see id. at Ex. 3, ¶ 101)), and the fact that Dougal is stayed until the arbitration finishes lessens the potential overlapping issues and the risk of inconsistent rulings.  Individual issues predominate. 

 

The Court’s understanding is that Dougal intends to move to lift the stay in Dougal for the limited purpose of amending her complaint to narrow her PAGA cause of action to a single claim regarding non-compliant commission agreements and to dismiss other claims that overlap with Leighton’s case.  (See, e.g., Reply, p. 3.)  If the Dougal court ends up allowing the amendment, individual issues will predominate even more.

 

B.        Convenience of the Parties, Witnesses, and Counsel 

   

This factor is neutral or favors denial.  Deciding common issues in one forum typically conveniences the parties, witnesses, and counsel, but the situation here is different.  Given the non-complexity of the cases, the key differences, and the predominating individual issues, and because the parties and counsel appear to live and work in multiple counties (Los Angeles County, Orange County, San Francisco County, and Alameda County), the Court is inclined to find that coordination would be inconvenient. 

 

C.        Development of the Cases and the Work Product of Counsel 

 

This factor favors denial.  Leighton is nearly two years old.  There has been mediation and written discovery, and trial is set to begin in September 2023 (the Leighton court recently continued the trial date from 3/14/23 to September 2023).  (See Reply, p. 2.)  Dougal is less than a year old.  Written discovery has not commenced, and it is stayed.  The cases are at different stages. 

 

In reply, Petitioner represents that Dougal’s counsel recently submitted a new pre-suit PAGA notice on behalf of a TRR employee named Melissa Morris (“Morris”).  Petitioner asserts:

 

The claims alleged [in the new pre-suit notice] appear to be identical to those in the Dougal Action, and therefore also overlap with the Leighton Action.  [Citation.]  In doing so, counsel for [] Dougal has made clear her resolve to litigate those claims which overlap with the Leighton Action, either through the presently filed Dougal Action or through yet another duplicative action.

 

(Reply, p. 3, underlined case names added; see also id. at Ex. 2.)

 

The Court disagrees.  The petition concerns Leighton and Dougal only.  Morris is not a party in either case, and there is no evidence suggesting that she will be added to either case.  The possibility that she may file her own action in the future is irrelevant and has no bearing on whether the current petition should be granted. 

 

D.        Efficient Use of Judicial Resources and Manpower 

 

This factor favors denial.  The analysis is the same as sections II.A. and II.B.  Since key differences exist and individual issues predominate, the threat of separate courts duplicating case efforts on the same issues and claims is low. 

 

E.        Calendars of the Courts 

 

This factor is neutral.  Petitioner’s brief does not address the specific, individual court calendars. 

 

F.         Duplicative and Inconsistent Rulings 

 

This factor favors denial.  The analysis is the same as sections II.A., II.B., and II.D.  There are key differences, and individual issues appear to predominate, so the likelihood that the courts will make duplicative or inconsistent key rulings, orders, or judgments if coordination is denied is reduced. 

 

G.        Likelihood of Settlement in the Absence of Coordination 

 

This factor is neutral or favors denial.  Neither case has settled so far, but coordination may cause Leighton’s January 2023 discovery conference and September 2023 trial to be moved, which might negatively impact settlement there.  Nothing in the record leads the Court to conclude that coordination will increase the chance of settlement. 

 

H.        Summary 

 

On balance, the coordination factors support denial.  The Court finds that the petition for coordination should be denied. 

 

III.      Site for the Coordinated Proceedings 

 

The factors considered in making a recommendation for the site of the coordination proceedings include: “[t]he number of included actions in particular locations;” “[w]hether the litigation is at an advanced stage in a particular court;” “[t]he efficient use of court facilities and judicial resources;” “[t]he locations of witnesses and evidence;” “[t]he convenience of the parties and witnesses;” “[t]he parties' principal places of business;” “[t]he office locations of counsel for the parties;” and “[t]he ease of travel to and availability of accommodations in particular locations.”  (Cal. Rules of Court, rule 3.530(b).)   

 

This issue is moot. 

 

IV.       Stay Request 

 

Petitioner asks the Court to stay the Included Actions pending coordination to “effectuate the purposes of coordination and promote the efficient utilization of judicial facilities and manpower.”  (Petitioner’s Brief, p. 18.) 

 

In light of the preceding analysis, the request is denied.