Filed Date: Nov. 20, 2019
Case Ongoing
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This lawsuit concerns individuals incarcerated in Santa Rita Jail in Alameda County, CA, who were allegedly forced to provide uncompensated labor for Aramark Correctional Services, LLC. When this suit was filed, Santa Rita Jail held individuals awaiting trial, individuals convicted of a crime awaiting sentencing, individuals in immigration detention, and individuals convicted of crimes serving county jail or state prison sentences. At the time of the lawsuit’s filing, Aramark Correctional Services, LLC was a private, for-profit company that sold food prepared by incarcerated individuals to third parties outside Alameda County.
On November 20, 2019, eight individuals—pre-trial detainees, detainees facing deportation, and convicted individuals serving sentences in Santa Rita Jail—filed a putative class action suit in the United States District Court for the Northern District of California. The plaintiffs sued the County of Alameda; its sheriff; Aramark Correctional Services, LLC; and ten unnamed defendants. Represented by a private law firm, the plaintiffs sought declaratory and injunctive relief, damages, and attorneys’ fees. The case was assigned to District Judge John S. Tigar.
The plaintiffs sued on behalf of themselves and a class of “all individuals incarcerated in Santa Rita Jail who perform or performed services for Aramark Correctional Services, LLC in their jail kitchen facility any time during the period that began four years prior to the filing of the original complaint in this action until the final disposition of this action.” The plaintiffs additionally sued on behalf of three subclasses. Three plaintiffs sued on behalf of the “Pretrial Detainee Subclass,” consisting of pretrial detainees who perform or performed services for Aramark. Three plaintiffs sued on behalf of the “Women Prisoner Subclass,” comprising all incarcerated women who perform or performed services for Aramark. One plaintiff sued on behalf of the “Immigration Detainee Subclass,” consisting of all incarcerated detainees awaiting immigration proceedings who perform or performed services for Aramark.
According to the complaint, Alameda County contracted with Aramark as early as July 1, 2015. The plaintiffs alleged that the contract allowed Aramark to employ individuals incarcerated in Santa Rita Jail without compensation. The plaintiffs prepared and packaged food in Santa Rita Jail’s industrial kitchen and sanitized the kitchen at the conclusion of the day’s food preparation. The plaintiffs claimed that Alameda County threatened to extend sentences, impose solitary confinement, and terminate employment if the plaintiffs refused to work without pay. In addition, the plaintiffs alleged that Alameda County typically assigned incarcerated men to work eight-hour, daytime shifts while incarcerated women were assigned to work four-hour, nighttime shifts. As a result, the women were deprived of equal opportunities to leave their cells and earn money. According to the complaint, when men incarcerated in Santa Rita Jail staged a worker strike to advocate for improved jail conditions in October 2019, Alameda County forced incarcerated women to work all shifts by threatening to withhold meals.
The plaintiffs brought ten claims in their original complaint. First, the putative pretrial detainee subclass, the immigration detainee subclass, and four plaintiffs claimed Alameda County and its sheriff violated the Thirteenth Amendment by coercing them to work without compensation. In their second claim, they alleged both County defendants and Aramark violated the federal Trafficking Victims Protections Act (18 U.S.C. § 1589) by forcing them to work without pay. The putative women prisoners subclass and three plaintiffs claimed the County defendants violated the Equal Protection Clause of the Fourteenth Amendment by assigning women shorter shifts at night and that all defendants violated the California Labor Code for failure to pay equal wages in violation of the California Equal Pay Act. Next, all plaintiffs and the putative class alleged the County defendants violated the Due Process Clause of the Fourteenth Amendment by failing to provide the plaintiffs an opportunity to be heard before denying their wages. They also claimed both the County defendants and Aramark violated the California Labor Code for failure to pay wages under Labor Code Sections 201, 202, and 218; failure to pay minimum wage under Labor Code Section 1194; and failure to pay overtime premium wages under Labor Code Section 1194. The plaintiffs brought one claim exclusively against Aramark for violating California’s Unfair Competition Law. Finally, they claimed all defendants violated California’s Bane Act, which prohibits the use of threats, intimidation, or coercion to interfere with the exercise of state or federal constitutional rights.
The plaintiffs sought declaratory relief that the defendants’ acts and practices violated the constitutional and statutory rights of the plaintiffs and the putative class and subclasses. They sought injunctive relief under 42 U.S.C. § 1983 and Ex Parte Young that would require the defendants to cease and desist from their acts and practices. Additionally, the plaintiffs sought general, special, and punitive damages in amounts to be determined under 42 U.S.C. § 1983 for financial and emotional injuries, such as emotional distress and the loss of wages and overtime premiums. The plaintiffs estimated that the injury and loss of money to the plaintiffs and the putative class and subclasses exceeded one million dollars and could be as much as several million dollars. The plaintiffs also sued for their costs and attorneys’ fees.
On December 13, 2019, Alameda County and its sheriff moved to dismiss the plaintiffs’ complaint. On January 17, 2020, Aramark separately moved to dismiss the plaintiffs’ complaint. On June 26, 2020, the court granted in part and denied in part both motions. For the federal claims, the court granted Aramark’s motion to dismiss the Trafficking Victims Protections Act claim against it with leave to amend, finding that the inference that Aramark witnessed the County defendants’ coercive tactics was too speculative based on the alleged facts. However, the court denied the County defendants’ motion to dismiss the plaintiffs’ federal claims because the plaintiffs were not required to plead exhaustion of administrative remedies.
For the state claims, the court granted the County defendants’ motion to dismiss the plaintiffs’ Labor Code and Bane Act claims against it as to one named plaintiff, with leave to amend, because the plaintiff did not sufficiently allege that he suffered an injury within one year of filing the class claim pursuant to the California Government Code. The court also granted the County defendants’ motion to dismiss the Labor Code and Bane Act claims against it as to two named plaintiffs for failure to comply with the Government Claims Act. Additionally, the court granted Aramark’s motion to dismiss the plaintiffs’ Equal Pay Act claim with leave to amend because the plaintiffs conceded that they did not allege unequal pay.
The court also denied in part and granted in part Labor Code claims against the defendants based on whether the plaintiffs were convicted or non-convicted individuals. For convicted individuals, the court granted the defendants’ motions to dismiss all Labor Code claims against all defendants without leave to amend. The court concluded that convicted incarcerated individuals were not covered by the California Labor Code. They therefore could not invoke Labor Code claims to recover wages.
For non-convicted individuals, the court denied both defendants’ motions to dismiss the Labor Code claim for failure to pay wages. The court also denied the County defendants’ motion to dismiss the Labor Code claims for failure to pay minimum wage and overtime. However, the court granted Aramark’s motion to dismiss the claims for failure to pay minimum wage and overtime because the plaintiffs failed to allege that they were employees of Aramark.
For the Unfair Competition Law claim, the court denied Aramark’s motion to dismiss this claim because the plaintiffs stated a Labor Code claim against Aramark for failure to pay non-convicted plaintiffs’ wages. Lastly, the court denied the County defendants’ motion to dismiss the Bane Act claim but granted Aramark’s motion to dismiss the Bane Act claim because the plaintiffs only alleged coercion by the County defendants and not Aramark.
On July 10, 2020, the plaintiffs amended their complaint. One individual was added as a named plaintiff in the amended complaint. Five of the original eight plaintiffs were added as representatives of the pretrial detainee subclass. The plaintiffs also reasserted all of their original claims, except for the Equal Pay Act claim, which they did not assert as to convicted individuals.
On August 14, 2020, both Alameda County and Aramark moved to dismiss the first amended complaint. The court granted in part and denied in part both motions on February 9, 2021. 519 F.Supp.3d 636 (amended and superseded by 2021 WL 12144269).
The court denied both defendants’ motions to dismiss the Trafficking Victims Protections Act claim because the plaintiffs did have standing to sue Aramark, both defendants could be held liable as primary offenders under the Act, and Aramark could be held liable as a venture offender under the Act.
The court granted Aramark’s motion in dismissing plaintiffs’ Labor Code Section 201 and 202 claim for failure to pay wages with leave to amend because plaintiffs did not plead sufficient facts that some form of termination or resignation occurred. The court disagreed with the plaintiffs’ argument that California Proposition 139 entitled them with a right to compensation because Proposition 139 did not mandate County defendants to enact a local ordinance before entering a joint employment venture with for-profit entities and because it did not state that a contract can function as an ordinance in the absence of a local ordinance governing county jail programs. The court also granted the County defendants’ motion to dismiss plaintiff’s Section 1194 claim for failure to pay overtime wages without leave to amend because the County defendants were exempt from state overtime laws.
The court denied Aramark’s motion to dismiss the plaintiffs’ Section 1194 claims for failure to pay minimum wage and overtime because the plaintiffs alleged sufficient facts to show that Aramark exercised some control over their working conditions. The court disagreed with the defendants’ assertion that the California Penal Code foreclosed the plaintiffs’ Labor Code claims. The court also denied Aramark’s motion to dismiss the plaintiffs’ UCL claim because the plaintiffs sufficiently alleged a Trafficking Victims Protections Act claim and Labor Code claims against Aramark and because any local, state, or federal law can serve as the predicate for an action under a UCL claim. Additionally, the court denied Aramark’s motion to dismiss the plaintiffs’ Bane Act claim because the plaintiffs alleged that Aramark intentionally interfered with the plaintiffs’ right to minimum and overtime wages under California Labor Code Section 1194 and because the plaintiffs were reasonably intimidated by Aramark’s threats to report the plaintiffs for discipline by the sheriff’s deputies if they refused to work.
The court denied the County defendants’ motion to dismiss the plaintiffs’ Section 1194 claim for failure to pay minimum wage because the plaintiffs sufficiently alleged that they were employed by the County defendants. The court also denied the County defendants’ motion to dismiss the plaintiffs’ Thirteenth Amendment claim because the plaintiffs’ allegation was sufficient to plead that the County defendants violated their Thirteenth Amendment rights and that the County defendants were acting under color of state law as administrators of Santa Rita jail. The court denied the County defendants’ motion to dismiss the putative women prisoner subclass’s equal protection claim because the plaintiffs sufficiently alleged that the County defendants’ practices deprived them of equal time outside their cells on the basis of gender. The court also denied the County defendants’ motion to dismiss the plaintiffs’ due process claim because the plaintiffs sufficiently stated that the County defendants denied their due process rights by withholding pay without an opportunity to be heard.
The court denied the County defendants’ motion to dismiss individual claims of three named plaintiffs whose state law claims were previously dismissed in the court order from June 26, 2020. The court held that the dismissal of their state law claims had no effect on their federal claims. The court also denied the County defendants’ motion to dismiss individual claims as to one named plaintiff because the named plaintiff’s claims were properly pleaded.
The defendants moved for leave to appeal the court’s decision. On June 24, 2021, the court granted leave to appeal, certified for interlocutory appeal the issue of whether the California Labor Code covered non-convicted individuals, and issued an amended order providing additional reasoning. The court maintained that California Proposition 139 did not confer upon the plaintiffs a right to compensation. However, the court added that it did not interpret Proposition 139 to preclude application of the Labor Code to the plaintiffs in all circumstances, disagreeing with the defendants’ argument that Proposition 139 authorized the local government to force the plaintiffs to work for Aramark without wages. The court also added reasoning as to why it disagreed with the defendants’ assertion that the California Penal Code foreclosed the plaintiffs’ Labor Code claims. It noted that its conclusion was supported by the fact that the plaintiffs worked for the benefit of Aramark and not for the county jail. The court stated that the Penal Code could not be interpreted to deny non-convicted detainees protections of the Labor Code because the Penal Code did not give guidance regarding the wages owed to non-convicted detainees working for a private company. It concluded that the non-convicted detainees working for a private company to supply goods to third parties outside of Alameda County were entitled to the protections of the Labor Code in the absence of regulation from the Penal Code or any relevant local ordinance.
On September 16, 2021, the defendants appealed to the Ninth Circuit Court of Appeals the district court’s decision that the California Labor Code covered non-convicted incarcerated individuals.
The district court referred the case to Magistrate Judge Sallie Kim on June 10, 2022 for discovery purposes. On July 1, 2022, the plaintiffs moved to certify a class and a subclass. The class consisted of “all pretrial detainees who work or who have worked for Aramark in the Santa Rita Jail Kitchen during the period November 20, 2015 and the present, without compensation.” The “Equal Protection Subclass” consisted of “all women who worked for Aramark in the Santa Rita Jail Kitchen during the period November 20, 2015 to the present, without compensation.”
On November 1, 2022, the Ninth Circuit Court of Appeals issued an order certifying to the California Supreme Court the question of whether non-convicted incarcerated individuals performing services in county jails for a for-profit company to supply meals within the county jails and related custody facilities have a claim for minimum and overtime wages under Section 1194 in the absence of any local ordinance prescribing or prohibiting the payment of wages. The Ninth Circuit stated that certification to the California Supreme Court was warranted because there was no controlling precedent and because the California Supreme Court’s decision could determine how this case turned out. 51 F.4th 1187.
Two days later, as a result of that decision, the district court stayed the case except for a pending motion for sanctions.
On January 11, 2023, the California Supreme Court granted the Ninth Circuit's request and agreed to hear the case (Case No. S277120). Oral argument was heard on February 6, 2024.
Back in the district court, on April 14, 2023, the district court granted sanctions against two plaintiffs for failing to appear at depositions. The order denied one plaintiff the ability to participate as a named class representative and dismissed the claims of another plaintiff with prejudice. The court did not award attorney’s fees to the defendants.
As of March 30, 2024, the parties are still awaiting the California Supreme Court’s opinion and proceedings in the district court are currently stayed.
Summary Authors
Bogyung Lim (3/8/2020)
Stephanie Kim (4/13/2023)
Venesa Haska (3/30/2024)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/16491559/parties/ruelas-v-county-of-alameda/
Beladi, Sara (California)
Glaser, Joel Perry (California)
Bahna, Christie Paulette (California)
Bosset, Eric C. (District of Columbia)
Chaput, Isaac Daniel (California)
See docket on RECAP: https://www.courtlistener.com/docket/16491559/ruelas-v-county-of-alameda/
Last updated Nov. 21, 2024, 12:52 p.m.
State / Territory: California
Case Type(s):
Special Collection(s):
Key Dates
Filing Date: Nov. 20, 2019
Case Ongoing: Yes
Plaintiffs
Plaintiff Description:
All individuals incarcerated in Santa Rita Jail who perform or performed services for Aramark Correctional Services, LLC in their jail kitchen facility any time during the period that began four years prior to the filing of the original complaint in this action until the final disposition of this action.
Plaintiff Type(s):
Public Interest Lawyer: No
Filed Pro Se: No
Class Action Sought: Yes
Class Action Outcome: Pending
Defendants
County of Alameda (Alameda), County
Aramark Correctional Services, LLC, Private Entity/Person
Defendant Type(s):
Facility Type(s):
Case Details
Causes of Action:
Ex parte Young (federal or state officials)
Trafficking Victims Protection Act (TVPA), 18 U.S.C. § 1589
Constitutional Clause(s):
Due Process: Procedural Due Process
Due Process: Substantive Due Process
Available Documents:
Outcome
Prevailing Party: None Yet / None
Nature of Relief:
Source of Relief:
Issues
General/Misc.:
Sanitation / living conditions
Discrimination Basis:
Affected Sex/Gender(s):
Jails, Prisons, Detention Centers, and Other Institutions: