Allison v. Dignity Health, 112 Cal. App. 5th 192 (2025)

Two former registered nurses filed a putative class action against their former employer, alleging various wage and hour claims. Although the trial court initially granted in part and denied in part plaintiffs’ motion for class certification, a different trial court judge subsequently granted Dignity Health’s motion to decertify the class based on post-certification discovery that refuted the trial court’s prior findings regarding predominance: “Accordingly, we hold the court did not abuse its discretion in concluding that individualized inquiries predominated Dignity’s showing to rebut its presumed liability and that the issue was otherwise not manageable on a class basis.” Dignity had submitted deposition testimony from class members evidencing a wide variation of relevant experiences regarding meal period compliance and premium payment requests. See also Harrington v. Cracker Barrel Old Country Store, Inc., 2025 WL 1803034 (9^th Cir. 2025) (district court must assess whether each opt-in plaintiff’s claim bears a sufficient connection to the defendant’s activities in the forum state in action arising under the Fair Labor Standards Act); Columbia Legal Services v. Stemilt AG Services, LLC, 2025 WL 1902292 (9^th Cir. 2025) (discovery in class action proceeding is presumptively public, and district court abused its discretion by prohibiting counsel from using information and documents obtained in discovery in other advocacy without prior approval of court).