Renteria-Hinojosa v. Sunsweet Growers, Inc., 2025 WL 2351203 (9^th Cir. 2025)

Annamarie Renteria-Hinojosa filed two putative class actions against her employer (Sunsweet Growers), alleging various wage and hour violations under California law, including PAGA. Renteria-Hinojosa’s employment was governed by two successive collective bargaining agreements (CBAs) between her union and Sunsweet. In response to the lawsuits, Sunsweet removed both actions to federal court, asserting federal question jurisdiction on the ground that the claims were preempted by Section 301 of the Labor Management Relations Act. Following removal to federal court, Sunsweet moved to dismiss both actions, arguing that the state law claims were either preempted by federal law or, in the alternative, were subject to arbitration under the applicable CBA. The Ninth Circuit held that the district court properly dismissed Renteria-Hinojosa’s untimely wage claims on the ground that she failed to exhaust the CBA dispute resolution procedures and remanded to state court the remaining non-preempted claims.

The Court further concluded that Renteria-Hinojosa’s claims for unpaid overtime, sick leave pay, meal and rest breaks, and adequate seating, arising under various provisions of the California Labor Code, the California Business & Professions Code, and the California Code of Regulations, were not preempted because they “do not arise exclusively from the CBAs, but rather from ‘rights conferred’ by state law” (citing Burnside v. Kiewit Pac. Corp., 491 F.3d 1053, 1059 (9^th Cir. 2007)). In “step two” of its analysis, the Court held that because the state law claims did not require interpretation of the “substantive provisions” of the CBAs, the claims were not preempted by Section 301. Finally, the Court held that the district court did not abuse its discretion by remanding the remaining state law claims to state court rather than exercising supplemental jurisdiction over them. See also Williams v. J.B. Hunt Transp., Inc., 2025 WL 2345897 (9^th Cir. 2025) (trucking company’s piece-rate pay plan complied with Cal. Lab. Code § 226.2, and company was properly granted judgment on the PAGA and cellphone reimbursement claims under Cal. Lab. Code § 2802).