LaCross v. Knight Transp. Inc., 775 F.3d 1200 (9th Cir. 2015)

In this putative class action, plaintiffs alleged that Knight Transportation had misclassified them as independent contractors when in fact they were employees who were not reimbursed their lease-related and fuel costs as required by Labor Code § 2802. Knight removed the case from state to federal court under the Class Action Fairness Act (“CAFA”), estimating the amount in controversy for reimbursing the drivers’ lease and fuel costs to be in excess of the $5 million minimum amount in controversy required for CAFA removal. Knight based its estimate on the actual fuel costs invoiced on Knight’s fuel cards for the first quarter of 2014 and then multiplied that amount ($2.3 million) by the 16 quarters in the four-year class period for a total of $36.8 million. Knight had an alternative, lower estimate of $21 million. The United States Court of Appeals for the Ninth Circuit held that Knight’s “chain of reasoning and its underlying assumption to extrapolate fuel costs… [is] reasonable” and that the employer had satisfied its obligation to prove that the amount in controversy exceeded $5 million. See also Ibarra v. Manheim Invs., Inc., 775 F.3d 1193 (9th Cir. 2015) (CAFA removal case remanded to district court so that both sides could submit evidence related to the contested amount in controversy).