Facts

On May 1, 2019, Lillian Audycki filed a class action suit in Santa Clara Superior against her employer Stanford Health Care. She began employment with Stanford Health in September 2014. On December 12, 2019, Tawnya Coogan, who worked as an hourly, non-union sales associate for Stanford Health from about June 6, 2016 to March 6, 2019, filed a similar complaint alleging wage-and-hour violations, as well as a representative action under Private Attorneys General Act (PAGA). Finally, the following year, on March 30, 2020, Joseph Ferlatte, who had begun working for Stanford Health as a kidney transplant social worker from September 9, 2019 to March 20, 2020, filed a class action complaint also against Stanford Health for various Labor Code violations and subsequently filed an amended complaint to add a PAGA claim. The cases were consolidated.

PLAINTIFFS' CONTENTIONS: Plaintiffs generally alleged that defendant failed to provide employees with complain meal and rest breaks; failed to include non-discretionary wages in their pay rates used to calculate sick pay; issued noncompliant wage statements; and committed other wage-and-hour violations. Specifically, plaintiffs contended that they had to work through their meal and rest period. Additionally, though employees routinely earned non-discretionary incentive wages such as shift differential wages, sick pay was paid as their base pay rate rather than the regular rate of pay. As such, defendant owed waiting time penalties for those whose employment ended. Moreover, plaintiffs were required to use their personal cell phones in discharging their duties without reimbursement. Plaintiffs further asserted that when they were paid shift differential wages, including for night and weekend shifts, the hours worked for shift differentials were redundantly listed in their wage statements' total hours worked section thus making the total hours worked incorrect. Because those differentials were excluded from their regular rates of pay used to calculate sick pay, their wage statements also failed to display the correct pay rate in this regard. Consequently, plaintiffs' wage statements reflected inaccurately all meal and rest period premiums to which they were entitled when denied off-duty meal and rest breaks.

DEFENDANT'S CONTENTIONS: Defendant denied plaintiffs' allegations and any liability of wrongdoing.

Settlement Discussions

On January 26, 2023, the parties participated in a full-day mediation with Steven Rottman, reaching a settlement agreement at that time.

Result

The parties settled for a non-revisionary gross settlement amount of $15 million.

Other Information

Consolidated with: Tawnya Coogan, on behalf of herself, all others similarly situated, and all aggrieved employees v. Stanford Health Care, and Does 1 through 10, inclusive: Case Number 19CV360010: Filed Dec. 12, 2019. Joseph Ferlatte, as an individual and on behalf of all others similarly situated v. Stanford Health Care, and Does 1 through 50, inclusive: Case Number 20CV365879: Filed March 30, 2020