Woodworth v. Loma Linda Univ. Med. Ctr., 93 Cal. App. 5th 1038 (2023)

Nicole Woodworth was a registered nurse at Loma Linda University Medical Center from December 2011 to June 2014.  In June 2014, she filed a putative class action against Loma Linda, alleging various wage and hour claims on behalf of herself and other employees.  She later amended her complaint to add a cause of action under the PAGA.  After several years of litigation, only her individual PAGA claim for failure to provide rest periods remained.

The Court of Appeal reversed many of the previous orders in the litigation, including, in part, the order denying class certification.  The appellate court determined that the trial court erred with respect to Woodworth’s proposed stand-alone wage statement class, which consisted of employees who received allegedly inaccurate wage statements and remanded for reconsideration certification of the class.  Woodworth alleged that prior to June 2018, the medical center issued wage statements that did not include a line showing total hours worked by an employee.  The trial court held that common questions did not predominate among the putative class because the wage statements of different workers at the medical center were too varied and determining liability would require an individualized review of the wage statements.  However, the appellate court said that a theory of liability would require different “samples” to prove liability, but it would not require a review of each wage statement.  The appellate court also held that trial courts may not strike or dismiss PAGA claims for a lack of manageability; instead, when facing “unwieldy” PAGA claims, trial courts may limit the scope of the claims or the evidence presented at trial.