9th Circ. Certifies MLB Classes in California Minimum Wage Class Action

Minor League Baseball players recently won Class certification for claims that they were denied California minimum wage.

In a 2-1 ruling, the Ninth Circuit three panel judges determined that the proposed Minor League player Classes are supported by sufficient evidence, meaning that they cannot be dismissed. As a result, the panel certified a national Fair Labor Standards Act (FLSA) collective and a California Class.

“As is true in all FLSA cases, underlying our decision today is the background principle that ‘because the FLSA is a remedial statute, it must be interpreted broadly,'” the panel wrote. “After all, the FLSA does not deal ‘with mere chattels or articles of trade but with the rights of those who toil.’”

Although the panel agreed to certify the national collective and California Class, the Ninth Circuit did not certify the proposed Arizona and Florida Classes. The panel determined that it wasn’t clear whether state laws or California laws should apply to those Classes.

Plaintiff Aaron S. and 44 other Minor League Baseball players filed their class action lawsuits in 2014, claiming that around 6,000 players without a union are only paid $1,100 a month during their five-month regular season. For spring and fall training, the players are allegedly not paid at all.

According to the California labor class actions, players routinely work 50 hours or more per week during their regular season and training periods. However, they claim to often be paid less than $10,000 a year. Players claim that their pay, or lack thereof, violates California minimum wage requirements.

“It is often said that baseball is America’s pastime,” U.S. Circuit Judge Richard A. Paez wrote. “In this case, current and former minor league baseball players allege that the American tradition of baseball collides with a tradition far less benign: the exploitation of workers.”

The current hourly minimum wage in California is between $11 and $12 an hour, depending on how many employees an employer has. According to the California Department of Industrial Relations, California monthly minimum wage is $2,133.52 for employers that have 26 or more employees and $1,955.74 for employers that have 25 or fewer employees.

According to a Forbes article, the MLB claims that minor league players are “seasonal apprentices” and therefore not protected under state and federal labor laws, but the players disagree. Although the league is working on a new agreement between minor and major leagues to take place after the current agreement expires in 2020, minor league players claim that they are still being severely underpaid.

The players reportedly support the Ninth Circuit’s recent decision, although they asked the panel to reconsider denying the proposed Florida and Arizona Classes. The certification of the nationwide collective and California Class will allow their California minimum wage claims to move forward.

“We look forward to proceeding to trial and proving that defendants’ pay practices for minor leaguers are illegal and woefully inadequate,” a player attorney told Bloomberg.

The Minor League Baseball Wage and Hour Class Action Lawsuits are Case Nos. 17-16245, 17- 16267, and 17-16276, all in the U.S. Court of Appeals for the Ninth Circuit.

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