Cruz v. Sun World Int’l, LLC, 2015 WL 9463140 (Cal. Ct. App. 2015)

Plaintiffs in this putative class action alleged off-the-clock work had been performed by employees, that meal and rest breaks were shortened, that the additional hour of pay for each meal or rest period they were denied was not paid, and that their wage statements were inaccurate. The trial court denied certification of the class, and the Court of Appeal affirmed, holding that common issues did not predominate over individual issues; the named plaintiffs’ claims were not typical of the class; the named plaintiffs were not adequate representatives of the class and a class action was not a superior means of adjudicating the claims because of the lack of commonality of issues. The Court also held that a group of workers who had been supplied by farm labor contractors was not a sufficiently ascertainable group for purposes of class treatment.