California Employment Law Blog

Navigating Class Actions: Insights from Miles v. Kirkland Stores, Inc.

Posted by Timothy B. Del Castillo | Mar 20, 2024 | 0 Comments

In California, the Labor Code safeguards employees' rights to duty-free breaks and fair compensation for all hours worked. Violations of these rights, affecting multiple employees in a similar manner, can lead to a class action lawsuit against the employer. 

However, navigating the path to a class action requires adherence to the Federal Rules of Civil Procedure, which demand a demonstration of commonalities in grievances that outweigh individual differences among the employees involved. In other words, those looking to start a class action need to prove that their complaints are shared broadly among the group, not just based on personal grievances or assumptions.

The case of Ariana Miles v. Kirkland's Stores, Inc. (2024) offers an insightful example of class action certification in action in an employment law context. Specifically, the case sheds light on the process of getting class actions certified in cases of California Labor Code violations and illustrates how courts weigh employer policies against employee rights.

Here, Ariana Miles brought forth a lawsuit against Kirkland's, alleging the company's rest break and bag check policies violated California labor laws, impacting employees uniformly. Initially, the district court rejected class certification for both claims, citing a lack of evidence for a universal policy violation and suggesting the necessity for individual case examinations.

The Ninth Circuit Court of Appeals later provided a differentiated perspective. It overturned the district court's decision regarding the rest break claim, pointing out Kirkland's uniform enforcement of the policy that prohibited employees from leaving the premises during breaks. On the other hand, the court upheld the decision on the bag check claim, agreeing that the policy's irregular enforcement warranted individual assessments, unsuitable for class action.

This case underscores crucial insights for both employers and employees. It highlights the importance of consistent and lawful policy enforcement to prevent class-wide litigation, emphasizing that uniform application of a policy can still result in liability if it contravenes labor laws. It also points out the challenges of class action certification, particularly for claims necessitating extensive individual inquiry. 

Employers are advised to regularly audit their labor practices with legal guidance to ensure compliance, while employees are encouraged to be vigilant about their rights and maintain proper documentation, as these practices are pivotal in legal disputes.

About the Author

Timothy B. Del Castillo

Tim Del Castillo is Founding Partner of Castle Law: California Employment Counsel, PC.


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