On August 16, 2019, the U.S. Court of Appeals for the Ninth Circuit ruled that minor league baseball players in Arizona and Florida could join minor leaguers in California in a multi-state employment class action against major league baseball ownership and its franchises. The players claim that baseball’s owners and teams failed to comply with the federal Fair LaborStandards Act and Arizona, California, and Florida labor laws by not paying them the required minimum wage. While the players were paid a minimum wage for a 40-hour work week, they claim they were required to work much more than 40 hours per week and were required to attend spring training and play games without being paid. The Ninth Circuit’s ruling means that thousands of minor league players who played in Arizona and Florida may join in the class action and seek damages for unpaid wages and overtime.
The Ninth Circuit reversed the district court’s refusal to certify the Arizona and Florida classes under Federal Rule of Civil Procedure 23(b)(3). Rule 23(b)(3) says that a class action may be maintained if questions of fact or law common to the class predominate over individual issues. The court reversed the district court’s ruling that the application of the laws of different states undermined the “cohesiveness” of the class. The court remanded the case back to the district court, ruling that class issues over whether the players were paid for their work predominated—even though Arizona, California, and Florida law will all apply in the case. The court held that the players could meet the predominance requirement through the application of the “continuous workday” rule, which says that once the beginning of the workday is triggered, an employee performs compensable work throughout the rest of the day until the employee completes his last principal activity.
The Defendants have not said whether they will appeal the ruling.