Facts

JetBlue Airways Corporation is a Delaware corporation with its headquarters in Long Island City, New York, and it operates out of airports throughout the United States. Christopher Booher worked as a flight attendant for JetBlue, based in California, from 2003 through October 2012. Patricia Reid also worked as a California-based flight attendant for JetBlue from 2011 through August 2015. During their time with JetBlue, both worked shifts lasting longer than 8 hours entirely within California, but they did not receive overtime pay. The wage statements JetBlue provided also failed to list the total hours worked. On March 16, 2015, Booher filed a class action lawsuit against JetBlue on behalf of himself and on behalf of all others similarly situated. In an amended complaint filed on August 31, 2015, Reid was added as a named plaintiff. On September 2, 2015, Reid provided notice to JetBlue and the Labor and Workforce Development Agency of various PAGA claims, and on November 9, 2015, a second amended complaint was filed to add the PAGA claims. JetBlue's flight attendants are not paid based on actual hours worked, but rather based on credits they earn under a formula-based compensation system in accordance with JetBlue's Flight Attendant Manual. The court granted summary judgment in JetBlue's favor on plaintiffs' minimum wage claims, holding that JetBlue's compensation plan complied with California law. Although the court ultimately ruled that JetBlue's wage statements were not fully compliant with California law as recently clarified by the California Supreme Court because the wage statements did not identify the actual hours flight attendants worked, the court held that JetBlue had a good faith belief that its wage statements complied with California law, which precluded liability.

PLAINTIFFS' CONTENTIONS: Plaintiffs contended that defendant failed to pay overtime as required by law; that defendants failed to timely pay wages due upon separation; that defendants failed to pay the minimum wage for all hours worked; and that defendant failed to provide accurate wage statements as required by law.

DEFENDANT'S CONTENTIONS: Defendant denied any wrongdoing and all of plaintiffs' material allegations. Defendant also contended that federal laws regulating airlines preempted state requirements. Defendant also contended that its compensation plan and wage statements complied with California law.

Result

A settlement agreement was reached wherein JetBlue admitted no wrongdoing but agreed to pay $3.6 million to settle class members' and PAGA claims.