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Central District of California Applied Wrong Legal Standards When it Denied Class Certification

The Ninth Circuit reverses a denial of a class certification. Plaintiff-Appellant Leyva seeks to represent approximately 538 employees of Defendant-Appellee Medline Industries, Inc. The putative class members are current and former hourly employees in the company’s three California distribution warehouses. The district court found that the putative classes appeared to meet the requirements of Rule 23(a) but nonetheless denied the certification holding that the putative class did not meet the requirements of Rule 23(b)(3) for two reasons. First, that common questions did not predominate over individual questions. Secondly, because the size of the class, alternative methods for resolving the dispute were superior due to probable difficulties in managing the case as a class action. The district court applied the wrong legal standard by concluding that individual questions predominate over common questions. The only individualized factor that the court identified was the amount of pay owed to the putative class members; however, damage calculations alone cannot defeat certification in this circuit. Further, the district court incorrectly held that class certification was not the superior method because of the difficulty of managing the class. While the district court concluded that certification was not the superior method, it did not suggest any other means for putative class members to adjudicate their claims.