2025’s Biggest California Wrongful Death Cases: Four Landmark Outcomes

California juries are making it clear: when a death could have been prevented, the financial consequences can be huge. In 2025, some of the state’s largest wrongful death verdicts showed a clear change in how jurors view loss, corporate responsibility, and deterrence. Some believe this shift is tied to a post-COVID perspective, where the human cost of wrongful death feels more real and personal, leading to higher verdicts.

Wrongful Death Cases in California in 2025: Significant Examples

These three cases show that landmark wrongful death outcomes in California can look very different. They include a record jury verdict against a large company, a major settlement with a public agency over alleged system failures, and a published appellate decision that could change how damages are handled in future cases. Each case highlights a different way to achieve accountability and shows why wrongful death litigation was a major focus in 2025.

Case #1: Mae K. Moore v. Johnson & Johnson, et al.

Court: Los Angeles County Superior Court

Case No.: 21STCV05513

A Summary of the Case: The plaintiffsSummary of the Case: The plaintiffs are the family or estate of Mae K. Moore, who are either wrongful death survivors or estate representatives, depending on the legal filings. The defendants are Johnson & Johnson and other related companies. The lawsuit claimed that Mae K. Moore’s illness and death were caused by asbestos exposure from the defendants’ products, and that the companies failed to provide warnings or acted improperly.

The case is a landmark 2025 California wrongful death case because of the sheer size of the award. Such a large amount signifies the continued escalation of “nuclear verdict” risk in California wrongful death/product exposure matters and the willingness of juries to impose extraordinary damages in cases involving alleged corporate safety failures.

Case #2: County of Los Angeles v. Superior Court (related to the Noah Cuatro wrongful death civil case)

Court: California Court of Appeals

Case No.: B339093 (Cal. Ct. App., 2d Dist., Div. 4)

Attached to Trial Case No. 20STCV24771 filed in the Los Angeles Superior Court

Summary of the Case: Evangelina “Eva” Hernandez, both personally and as the legal representative for the child’s estate and siblings, filed a wrongful death lawsuit. She claimed that child welfare authorities failed to protect the child and did not act on clear warning signs of danger, including not following through on protective steps mentioned in the court record. In September 2025, LA County supervisors agreed to a $20 million settlement with the child’s family.

The Noah Cuatro wrongful death case was one of the most notable public-entity settlements in California in 2025. It brought attention to system accountability and involved a large settlement and significant public attention.

Case #3: Ng v. Superior Court

Case No.: G064257 (Cal. Ct. App., 4th Dist., Div. 3)

Underlying Trial Court Case Info: Orange County Superior Court, Case No. 30-2023-01360050

Summary of the Case: Joely Ng sued Los Alamitos Medical Center and doctors for medical malpractice and wrongful death after her husband, Kenneth Ng, allegedly received negligent care following a G-tube problem and improper placement. Ng developed sepsis and died three months later. The case led to a published appellate decision about whether wrongful death and survival or medical negligence claims can each have separate MICRA noneconomic damage caps, which is a key issue in California medical malpractice and wrongful death cases.

Ng v. Superior Court is a landmark 2025 wrongful death case because it changes how damages can be claimed and valued in medical malpractice wrongful death cases. It clarifies how wrongful death and survival claims are treated under MICRA’s cap rules.

Wrongful death cases are about more than just money, but the 2025 outcomes show something important: California juries and courts are more willing to impose serious consequences when families claim a preventable loss was caused by corporate wrongdoing, system failures, or poor care. Whether the result is a large verdict, a major public settlement, or a new legal precedent, the main theme is accountability and the need for careful, evidence-based legal work from the start.

If your family has lost a loved one and you think negligence or wrongdoing was involved, the wrongful death attorneys at Blumenthal Nordrehaug Bhowmik De Blouw LLP can help you learn about your legal options and what to do next. Contact our offices in Los Angeles, San Diego, San Francisco, Sacramento, Riverside, or Chicago to talk about how you may be able to seek accountability under California law.

Did Starbucks Break New York City’s Fair Workweek Scheduling Law? $38.9 Million

Alleged labor law violations led to a multi-year investigation into Starbucks’ scheduling practices, resulting in a $38.9 million settlement, the largest worker-protection resolution in New York City history.

Matter: DCWP v. Starbucks Corporation (Consent Order / Settlement (administrative enforcement))

Enforcing agency: NYC Department of Consumer and Worker Protection (DCWP)

Public announcement date: December 1, 2025

Total settlement: $38.9 million

Restitution: $35.5+ million to workers

Civil penalties/costs: $3.4 million

Workers covered: 15,000+ hourly NYC Starbucks workers (July 2021–July 2024)

Note: This was not a court class action with a judicial “case number” in the way civil lawsuits are docketed; it was a DCWP enforcement matter resolved by a Consent Order (DCWP’s settlement format).

The Parties Involved: The Workers and Their Employer

The DCWP stated that the settlement will benefit more than 15,000 hourly Starbucks employees in New York City who worked during the specified period. Starbucks Corporation, the employer, is subject to the agreement, which covers scheduling practices at over 300 city locations.

A Brief Timeline of Events Leading to the Settlement:

• 2022: The investigation began due to multiple worker complaints at Starbucks locations.

• Using employee reports and company data they gathered as evidence, the DCWP identified broader patterns of alleged violations, leading to an expanded investigation across Starbucks locations citywide.

• Over 500,000 violations of the city’s Fair Workweek Law have been identified since 2021.

• The case was resolved through a Consent Order requiring monetary relief and future compliance with labor laws.

What Was the Main Issue Being Considered During the Investigation?

The central issue considered was whether Starbucks’ scheduling and hours practices for New York City hourly workers violated the Fair Workweek Law, particularly regarding predictable schedules, access to additional hours, and limits on reductions in hours and on schedule changes.

An Overview of the Alleged Violations Workers Cited:

• Unstable and unpredictable schedules made it difficult for workers to plan for child care, education, secondary employment, and other obligations.

• Unlawful weekly hour reductions; Starbucks routinely reduced its employees’ hours by 15% in one week, which is a violation of Fair Workweek protections.

• Blocking access to additional hours through picking up shifts, which contributed to involuntary part-time employment.

What Are the Protections Provided by Fair Workweek for NYC Workers?

• Employers must provide schedules 14 days in advance

• Employers must offer premium pay for schedule changes

• Employers must allow employees to decline extra time

• Employers must allow employees to pick up new shifts before hiring new staff

• Employers may not schedule workers for consecutive closing and opening shifts without written consent and a $100 premium

• Hour reductions are limited to over 15% without just cause

Learn More About the Starbucks Settlement for NYC Workers:

The settlement totals $38.9 million, including:

• $35.5+ million in restitution to impacted workers

• $3.4 million in civil penalties and costs

• A forward-looking requirement that Starbucks comply with the Fair Workweek Law going forward

• The DCWP stated that most hourly Starbucks employees in New York City will receive $50 for each week worked between July 4, 2021, and July 7, 2024. For example, an employee who worked 78 weeks could receive $3,900.

• The DCWP also stated that employees who experience violations after July 7, 2024, may be eligible for compensation by filing a complaint. The settlement also addressed issues related to layoffs and reinstatement rights under the law.

Worker-Protection Settlement: Why Was This a 2025 Landmark Case?

The DCWP v. Starbucks matter was notable for a few reasons:

1. Scale of Relief & Coverage: The almost $40M settlement covered over 15,000 workers, making this one of the most significant scheduling-law enforcement outcomes in 2025.

2. Fair Workweek Enforcement: This case shows that Fair Workweek laws are enforceable and that substantial restitution and penalties can be obtained for violations involving hour reductions and shift management.

3. Operational Practices & Liability: The DCWP reported over 500,000 violations, demonstrating how widespread scheduling decisions across many locations resulted in massive exposure.

FAQ: DCWP v. Starbucks & Fair Workweek for NYC Workers

Q: What is NYC’s Fair Workweek Law intended to protect?

A: The law is designed to protect the rights of fast food workers by requiring more predictable schedules, limiting last-minute changes and hour reductions, and ensuring workers have a fair opportunity to claim shifts that become available.

Q: Is this different from an FLSA overtime case?

A: Yes, the Fair Workweek Law addresses scheduling stability and hours practices, including advance notice, schedule changes, access to shifts, and protections related to hour reductions, rather than overtime hour calculations, classification, or overtime pay rate calculations.

Q: Does a “Consent Order” mean Starbucks admitted wrongdoing?

A: Not necessarily. A consent order is a settlement document used by the DCWP to resolve allegations and impose enforceable terms, such as payment and compliance obligations.

Q: What should employees do if they think their schedule rights were violated?

A: Workers should document schedule postings, changes, and hour reductions, and may seek relief by filing a complaint with the DCWP or consulting legal counsel regarding potential claims under relevant laws.

Individuals who believe their employer manipulated schedules, unlawfully reduced hours, restricted access to available shifts, or otherwise violated wage-and-hour or worker-protection laws may seek assistance from the employment law attorneys at Blumenthal Nordrehaug Bhowmik De Blouw LLP. The firm’s offices in Los Angeles, San Diego, San Francisco, Sacramento, Riverside, and Chicago are available to discuss potential claims for unpaid compensation and accountability.

Did Poultry Processors Fix Worker Wages? $398.05 Million Class Settlement Receives Final Approval in 2025

A sweeping worker class action accused many of the country’s largest poultry processors of secretly coordinating to keep compensation artificially low in an alleged wage-fixing scheme.

Case: Jien, et al. v. Perdue Farms, Inc., et al.

Court: U.S. District Court for the District of Maryland

Case No.: SAG-19-2521 (also docketed as No. 1:19-cv-02521)

Final approval date: June 5, 2025

Total settlements approved: $398.05 million

Who Were the Parties in the Case?

The plaintiffs are a proposed class of non-supervisory poultry-industry workers (typically production and maintenance employees) who allege they were harmed by an industry-wide agreement that depressed wages and benefits for workers in their positions at poultry processing facilities. Perdue Farms, Inc. and other poultry processors were the defendants in the case, with the plaintiffs alleging they worked together to use a wage-suppression conspiracy to their financial advantage.

A Brief Run Down of the Case History:

The litigation began in 2019 in the United States District Court for the District of Maryland. Plaintiffs alleged that major poultry companies used shared wage data and coordinated practices to reduce competition for labor and minimize their own labor costs. This kept compensation below what a competitive market would have set and allegedly limited workers in the industry's ability to earn a fair wage.

The case stretched across several years, including amended pleadings, motion practice, and discovery. During this time, groups of defendants reached separate settlement agreements at various points. By late 2024/early 2025, additional settlements pushed the combined total close to $400M, with the recovery described in public reporting as one of the largest of its kind for worker antitrust claims.

The court granted final approval to the settlements totaling over $398 million on June 5, 2025, and certified the settlement class to distribute the recovery.

The Main Question the Court Considered in the Case: Jien, et al. v. Perdue Farms, Inc., et al.

There was a fairly high-stakes question at the center of this case: Did poultry processors unlawfully conspire to suppress worker compensation by coordinating wages and benefits, rather than competing for workers? If the court determined the answer to be yes, the action was a violation of federal antitrust law.

What Were the Allegations Against the Poultry Farms?

The workers alleged that participating companies shared sensitive compensation information and used it to align pay practices across the industry, reducing normal competitive pressure that would otherwise increase wages.

Unlike a typical overtime or off-the-clock lawsuit, the theory here was not that workers were denied overtime premiums under wage-and-hour statutes. Instead, the allegation was that an anti-competitive agreement distorted the labor market, leading to lower pay rates than they should have been for the work performed.

Jien, et al. v. Perdue Farms, Inc., et al.: Settlement Outcome

The Maryland federal court granted final approval to settlements totaling just over $398 million, making it a Landmark Worker-Pay Settlement in 2025 for three practical reasons:

1. The size of the recovery. A $398.05 million class settlement is extraordinary in worker-pay litigation, even before considering the number of potentially eligible workers nationwide.

2. It targets wage-fixing directly. The case reflects an ongoing trend of using antitrust law to challenge alleged wage suppression, treating workers as participants in a competitive market that the law protects from collusion.

3. Industry-wide impact. The allegations and settlements involved multiple major processors across the poultry sector, making the litigation a major event for how large employers manage compensation benchmarking and information sharing.

FAQ: Jien, et al. v. Perdue Farms, Inc., et al.

Q: What’s the difference between “wage-fixing” and an overtime violation?

A: Overtime cases typically allege violations of wage-and-hour statutes (like the FLSA). Wage-fixing cases generally allege an anti-competitive agreement that suppresses wages; an antitrust theory focused on market competition.

Q: Who could be included in the settlement class in this case?

A: The settlement described the class as non-supervisory workers employed at poultry processing operations and related facilities during a certain time period (subject to the class definitions approved by the court).

Q: For a class action, what does “final approval” mean?

A: Final approval means the court has reviewed the class action settlement’s terms and concluded it is legally acceptable under current standards. Final approval clears the way for administration and payments.

Q: How are settlement payments typically calculated for this type of case/settlement?

A: Payment formulas commonly consider factors like how long a person worked during the class period and compensation-related information, with payments made on a pro rata basis under the plan approved by the court.

If you believe your employer kept your pay unlawfully low, failed to pay you all wages owed, or engaged in practices that shortchanged workers, the employment law attorneys at Blumenthal Nordrehaug Bhowmik De Blouw LLP can help you understand your options. Contact the firm’s offices in Los Angeles, San Diego, San Francisco, Sacramento, Riverside, or Chicago to discuss potential wage-and-hour or related worker-protection claims.

Did Disneyland Underpay Workers Under Anaheim’s Living Wage Ordinance? $233 Million Settlement Approved for 51,000+ Employees

When the long-running wage-and-hour class action against Disneyland finally ended, it was resolved with a $233 million settlement. Approved in September 2025, the settlement covered more than 51,000 of the popular amusement park resort’s employees.

Case: Grace et al. v. Walt Disney Co. et al.

Court: California Orange County Superior Court

Case No.: 30-2019-01116850

The Plaintiffs in the Case: Grace et al. v. Walt Disney Co. et al.

The plaintiffs are a group of current and former nonexempt hourly workers at Disney theme parks and hotels in Anaheim, California, who alleged they were not paid the minimum hourly rate and related service-charge amounts required under Anaheim’s Living Wage Ordinance during the covered period.

The Defendants in the Case: Grace v. Walt Disney Co.

In Grace et al. v. Walt Disney Co. et al., the defendants are The Walt Disney Company and Walt Disney Parks and Resorts U.S., Inc. To further define the relationship between the two listed defendants in the case, the Walt Disney Company is the parent holding company, and Walt Disney Parks and Resorts U.S., Inc. is commonly the operating subsidiary for parks/resorts.

A Brief Rundown of the Case History

The case against Disneyland questioned whether Disney was required to pay a higher hourly wage under Anaheim’s Living Wage Ordinance (Measure L), and if so, what back pay was owed to employees whose wages did not meet the minimums. When Measure L was approved in 2018, it established a living wage requirement for some types of hospitality employers tied to the Anaheim Resort District and/or city subsidies (a starting rate of $15/hr in 2019, with scheduled increases thereafter).

In December 2019, workers filed a putative class action in Orange County Superior Court, alleging that the Disneyland Resort violated Measure L by failing to pay the required minimum wage.

Litigation commenced - and continued - for several years while the parties disputed whether Disney was subject to the ordinance and, if so, what remedies would apply to the situation. A settlement was preliminarily approved in spring 2025, notices were issued to class members in May 2025, and the court granted final approval in mid-September 2025.

Main Question in the Case:

The main question in the case is whether the Living Wage Ordinance applies to Disney and, if so, whether hourly employees were underpaid relative to the ordinance’s minimum wage requirement.

Summary of the Allegations in the Wage and Hour Complaint:

The plaintiffs alleged that Disney failed to pay covered hourly workers the minimum hourly wage and related amounts mandated by Anaheim’s Living Wage Ordinance, beginning January 1, 2019.

Public settlement materials describe the ordinance as requiring escalating minimum hourly rates over time, including (as presented in the settlement information) $15/hour for 2019, followed by annual increases through 2025.

2025 Settlement Outcome of the Disneyland Wage and Hour Class Action

The court approved a $233,000,000 settlement for a reported class of 51,478 employees with $179.575 million distributed to class members, $17.475 million designated for civil penalties, and the remainder covering fees/costs, etc.

Settlement administration updates indicated that the order approving the settlement became “final” on November 17, 2025 (the “Effective Date” referenced by the administrator), after which payments began processing.

Why This Was a Landmark California Wage-and-Hour Settlement in 2025

1. The number of workers affected. In 2025, California reached one of the biggest wage-related settlements with a single employer. It covered more than 51,000 current and former employees.

2. Local laws that set minimum wages could lead to a lot of exposure. This disagreement was about a city law that raised wage requirements, not the state or federal minimum wage. The discussion shows how municipal wage laws can significantly increase the back pay that big businesses must pay when they work under public agreements or benefits.

3. Fines and back pay. The settlement structure showed how wage-and-hour cases in California can include both compensation and penalty components, with a large LWDA penalty component alongside employee payments.

FAQ: The Disneyland Wage and Hour Case

Q: What is Anaheim's "Living Wage Ordinance" (Measure L)?

A: Measure L, a voter-approved ordinance in Anaheim, establishes a higher minimum wage for specific hospitality employers linked to city subsidies and/or the Resort District. It will begin at $15 per hour in 2019 and gradually increase.

Q: Who can file a wage and hour lawsuit?

A: Any employee who believes their employer failed to pay all wages owed—such as minimum wage, overtime, meal/rest breaks, or off-the-clock work—may be able to file a wage-and-hour lawsuit, either individually or with other workers in a class or collective action.

Q: Who was covered by the settlement class?

A: The settlement class was defined to include nonexempt current and former workers employed at Disney theme parks and hotels in Anaheim during the covered period who were not paid at least the amounts required by the ordinance.

Q: What’s the Benefit of Filing a Wage and Hour Lawsuit?

A: Filing a wage-and-hour lawsuit can help you recover unpaid wages (and often additional damages and penalties), hold your employer accountable for illegal pay practices, and in some cases push the employer to change policies that impact you and your coworkers.

Q: Was Disney found liable by the court during the trial?

A: A court-approved class action settlement ended the litigation without a verdict on the merits of the case.

Q: What is Anaheim's "Living Wage Ordinance" (Measure L)?

A: Measure L, a voter-approved ordinance in Anaheim, establishes a higher minimum wage for specific hospitality employers linked to city subsidies and/or the Resort District. It will begin at $15 per hour in 2019 and gradually increase.

If you believe you were underpaid, denied legally required wage increases, or did not receive all compensation required under California wage laws or local wage ordinances, the employment law attorneys at Blumenthal Nordrehaug Bhowmik De Blouw LLP can help you assess your potential claims. Contact one of the firm’s offices in Los Angeles, San Diego, San Francisco, Sacramento, Riverside, or Chicago to discuss your options for pursuing unpaid wages and accountability under the law.

Did Cracker Barrel Face a Nationwide Overtime Lawsuit That the Ninth Circuit Narrowed on Jurisdiction Grounds?

Current and former Cracker Barrel servers filed a nationwide wage-and-hour lawsuit alleging violations of labor laws related to tip pooling practices.

Case: Harrington, et al. v. Cracker Barrel Old Country Store, Inc.

Court: U.S. Court of Appeals for the Ninth Circuit

Ninth Circuit Docket Nos.: 23-15650 and 24-1979

Decision Date: July 1, 2025

Trial Court: U.S. District Court for the District of Arizona

District Court Case No.: 2:21-cv-00940-DJH

Get to Know the Plaintiffs in the Case:

The plaintiffs, Andrew Harrington, Katie Liammaytry, Jason Lenchert, and Dylan Basch, are current and former Cracker Barrel employees who allege violations related to pay practices for tipped workers.

Learn More About the Defendant in the Case:

The defendant, Cracker Barrel Old Country Store, Inc., is a restaurant chain incorporated and headquartered in Tennessee.

Case History: Harrington, et al. v. Cracker Barrel Old Country Store, Inc.

The case was filed in Arizona District Court as an FLSA collective action under 29 U.S.C. § 216(b). The district court authorized notice to a proposed collective that included servers in multiple states where Cracker Barrel allegedly used a tip-credit pay model, using the standard two-step conditional certification process.

Cracker Barrel objected to nationwide notice, arguing that some workers may be subject to arbitration agreements and that the Arizona court lacked personal jurisdiction over claims by out-of-state opt-ins with no connection to Arizona. The district court still authorized nationwide notice based on an Arizona-based named plaintiff. Cracker Barrel responded by obtaining an interlocutory appeal. As a result, the case ended up in the Ninth Circuit Court.

What is the Main Question Considered in the Case?

The main issue was whether the Supreme Court’s Bristol-Myers Squibb personal-jurisdiction framework applies to FLSA collective actions in federal court. The court needed to decide if it must evaluate personal jurisdiction for each opt-in plaintiff’s claim instead of relying on a named plaintiff’s forum connection to support claims nationwide.

Summary of the Allegations: Harrington, et al. v. Cracker Barrel Old Country Store, Inc.

The plaintiffs alleged that Cracker Barrel violated the FLSA regarding wages for tipped employees, particularly in its use of the federal tip credit. Although the Ninth Circuit’s opinion focused on procedural issues, the case was a nationwide wage-and-hour dispute over tip-credit practices.

The Ninth Circuit’s Ruling in Harrington, et al. v. Cracker Barrel Old Country Store, Inc.

The Ninth Circuit made three key holdings:

• The two-step conditional certification process is permissible. The panel found the district court did not abuse its discretion by using this procedure at the preliminary stage.

• If the validity of arbitration agreements is genuinely disputed, the district court is not required to resolve arbitrability for absent employees before authorizing notice.

• The Ninth Circuit held that Bristol-Myers applies to FLSA collectives. When a court relies on specific jurisdiction, it must determine whether each opt-in plaintiff’s claim is sufficiently connected to the defendant’s contacts with the forum state. The panel vacated the nationwide notice order and remanded the case because the district court did not conduct the Bristol-Myers analysis.

• In a separate memorandum disposition issued the same day, the Ninth Circuit also addressed Cracker Barrel’s motion to compel arbitration as to one plaintiff’s claims.

Why This Was a Landmark Wage-and-Hour Case in 2025

The decision in this wage and hour case didn’t change overtime law, but it reshaped where and how nationwide wage and hour cases can be litigated in the Ninth Circuit.

1. Limits nationwide FLSA collectives filed outside an employer’s home state.

2. Affects early case strategy

FAQ: Harrington, et al. v. Cracker Barrel Old Country Store, Inc.

Q: What is an FLSA “collective action”?

A: It is a procedure under the FLSA that allows employees to pursue overtime or minimum-wage claims together, but workers generally must opt in by filing a written consent.

Q: What did the Ninth Circuit actually “narrow” in this case?

A: The court narrowed the ability to send nationwide notice from a forum that may not have personal jurisdiction over the claims of out-of-state workers. The district court must evaluate jurisdiction for each opt-in claim when the case relies on specific jurisdiction.

Q: Does this decision mean workers can never bring nationwide FLSA cases?

A: Not necessarily. It means plaintiffs must choose a forum that can support jurisdiction over the broader set of claims (for example, where the employer is subject to general jurisdiction) or tailor the collective to workers whose claims have a sufficient connection to the forum.

Q: Did the Ninth Circuit decide whether Cracker Barrel violated wage laws?

A: No. The opinion addressed procedural issues—notice, arbitration timing, and personal jurisdiction—not the ultimate merits of the wage claims.

If you believe you were denied overtime pay, paid under an unlawful tip-credit practice, or not compensated for all hours worked, the wage-and-hour attorneys at Blumenthal Nordrehaug Bhowmik De Blouw LLP can help you evaluate your options under federal and state law. Contact the firm’s offices in Los Angeles, San Diego, San Francisco, Sacramento, Riverside, or Chicago to discuss potential unpaid wage claims.

Did the Logan Inn’s Tip Pool Violate Wage Laws? Third Circuit Ruling Reshapes FLSA Settlements

In 2025, the Third Circuit issued a precedential decision on Lundeen v. 10 W. Ferry St. Operations LLC, clarifying the FLSA’s opt-in rule as a procedural requirement.

Case: Lundeen v. 10 W. Ferry St. Operations LLC

Court: U.S. Court of Appeals for the Third Circuit

Appellate Docket No.: No. 24-3375

District Court: U.S. District Court, Eastern District of Pennsylvania

District Court Case No.: 2:24-cv-00109-JDW

Get to Know the Parties: Lundeen v. 10 W. Ferry St. Operations LLC

Graham Lundeen, the plaintiff, worked as a bartender and server for the defendant at New Hope’s Logan Inn in Pennsylvania from September 2021 through December 2022. He filed the case on behalf of himself and other similarly situated hourly bartenders and servers.

A Brief History of the Case:

Lundeen filed the original wage and hour complaint in January 2024 in the Eastern District Court of Pennsylvania, alleging federal and state labor law violations related to the Inn’s tip-pooling policy. Filed as a hybrid case, the two claims proceeded separately - the FLSA claim as a collective action (opt-in) and the PMWA claim as a class action (opt-out). Parties agreed to a conditional certification of the FLSA collective, and notice was issued to eligible workers. (Lundeen and 9 others filed written consents). After discovery and a settlement conference, the parties proposed a settlement in June 2024. The proposal included an opt-out class settlement to resolve state wage claims and release FLSA claims for class members who did not opt out, even if they never opted in to the FLSA collective. The district court denied preliminary approval, stating that, under labor law, written consent to serve as a party plaintiff is required, so the settlement cannot require class members who did not opt in to release FLSA claims. The Third Circuit vacated the district court’s decision and remanded the case.

What Was the Main Question in the Case?

The central question was whether the FLSA’s opt-in requirement in 29 U.S.C. § 216(b) prohibits an opt-out Rule 23 class settlement from releasing unasserted FLSA claims held by class members who never opted into the FLSA collective.

Summary of the Allegations

Lundeen alleged that the Logan Inn operated a tip pool funded by bartenders’ tips, but, according to the complaint, the bar manager (a salaried supervisory employee) allegedly also received distributions from this pool. The plaintiff argued that this practice violated both federal and Pennsylvania wage laws.

What is a Tip Pool?

A tip pool is a shared fund of tips redistributed among a designated set of workers. Employees collect all or a portion of their tips into a shared fund/tip pool, with the original intent to ensure an equitable distribution of gratuities. However, the tip pool creates the opportunity for mismanagement that can lead to dissatisfaction and labor law complaints.

The Third Circuit’s Decision

The Third Circuit vacated the order and remanded so the district court could consider the settlement for fairness under Rule 23. While § 216(b) sets the procedure for litigating FLSA claims (opt-in), it does not determine the conditions for waiving or releasing claims through settlement.

FAQ: Wage and Hour Violations

Q: Why was Lundeen v. 10 W. Ferry St. Operations LLC a landmark wage and hour case in 2025?

A: The case addresses resolving hybrid cases, a recurring issue in wage and hour litigation, efficiently and fairly.

Q: What does this case change for wage-and-hour settlements?

A: It provides precedential support for resolving hybrid cases through an opt-out Rule 23 settlement that can include FLSA releases, subject to judicial review for fairness and adequate notice.

Q: What is Rule 23?

A: Courts use the familiar Rule 23 framework to evaluate settlements for notice, opportunity to opt out, objections, and judicial review.

Q: What Can You Do If Your Employer Violates Labor Law?

A: If you believe your employer’s business policies or standard practices violate labor law, reach out to an experienced local employment law attorney to discuss your options.

Q: What is the difference between an FLSA “collective action” and a Rule 23 “class action”?

A: In an FLSA collective action, workers must generally opt in by filing a written consent. In a Rule 23 class action, workers are included unless they opt out after receiving notice.

Q: Did the Third Circuit rule that the settlement in Lundeen was automatically fair?

A: No. The court did not approve the settlement. It held only that § 216(b) does not prohibit the settlement structure and remanded the case for a full Rule 23 fairness review.

If you believe your tips were improperly diverted, your employer used an unlawful tip credit, or you were denied legally owed wages, the employment law attorneys contactat Blumenthal Nordrehaug Bhowmik De Blouw LLP can help you assess your wage-and-hour rights and options. Contact the firm’s offices in Los Angeles, San Diego, San Francisco, Sacramento, Riverside, or Chicago to discuss pursuing unpaid compensation and accountability under the law.

Did Lion Farms Violate Migrant Farmworker Protections? A 2025 Landmark Federal Enforcement Case

In 2025, the federal enforcement case against Lion Farms LLC concluded with a consent judgment and permanent injunction. The employer and its owners were ordered to pay $128,899.50 in back wages and civil money penalties for alleged violations affecting migrant and seasonal agricultural workers.

Case: Chavez-DeRemer v. Lion Farms, LLC

Court: U.S. District Court for the Eastern District of California

Case No.: 1:25-cv-00312-KES-EPG (also listed as 1:2025cv00312)

More About the Plaintiff: Chavez-DeRemer v. Lion Farms, LLC

The U.S. Secretary of Labor, Lori Chavez-DeRemer, took action through the Department of Labor to address claims that MSPA and its rules were violated. The U.S. Department of Labor investigated a crash involving workers on February 23, 2024, which prompted the action.

Defendants in the Case: Chavez-DeRemer v. Lion Farms, LLC

The defendants are Lion Farms LLC and its owners and operators: Bruce Lion, Alfred Lion, and Daniel Lion.

A Brief Case History: Chavez-DeRemer v. Lion Farms, LLC

After a car accident on February 23, 2024, that killed seven employees and seriously hurt another while they were on their way to work, the U.S. Department of Labor's Wage and Hour Division looked into Lion Farms. The Department said the employer did not follow the federal government's rules for transporting migrant and seasonal agricultural workers.

The Secretary of Labor filed the lawsuit on March 14, 2025, in the Eastern District of California. The case was resolved by a Consent Judgment and Permanent Injunction entered on August 26, 2025.

What Did the Court Need to Take Into Account?

In this enforcement action, the court had one main question to consider. Did Lion Farms and its owners comply with MSPA regulations? (Particularly the regulations pertaining to safe transportation, accurate wage-statement disclosures, and lawful wage payments).

What Were the Case's Alleged Violations?

The Department of Labor alleged the following MSPA violations:

• Unsafe or illegal transportation practices, including use of vehicles and drivers that did not meet MSPA licensing and insurance requirements.

• Charging workers a transportation fee that investigators deemed unlawful due to the alleged transportation violations.

• Failure to provide required wage statement information, such as workers’ permanent addresses and the employer’s identification number.

Unpaid wages: The agency calculated $39,013 in back wages owed to 12 employees.

The consent judgment also references alleged MSPA violations from October 16, 2022 through February 24, 2024.

What Was the Outcome of the Case?

The August 26, 2025 consent judgment:

1. Entered judgment totaling $128,899.50, consisting of: $39,013.00 in back wages, and $89,886.50 in civil money penalties.

2. Imposed a permanent injunction requiring future compliance and prohibiting further MSPA violations.

Why This 2025 Wage-and-Hour Enforcement Case Was Historic

Regarded as a landmark case for 2025, this wage-and-hour enforcement combined back pay/wage relief, significant civil money penalties, and a permanent injunction in a matter involving alleged safety and pay violations affecting vulnerable agricultural workers, despite the fact that MSPA is a farmworker protection statute rather than the FLSA.

FAQ: Chavez-DeRemer v. Lion Farms, LLC

Q: What is MSPA?

A: MSPA is a federal law setting protections for migrant/seasonal agricultural workers. Protections include requirements regarding disclosures, wage statements, and certain working-condition safeguards (including transportation safety standards).

Q: What monetary relief did the court order in the Chavez-DeRemer v. Lion Farms, LLC case?

A: The consent judgment totaled $128,899.50 ($39,013.00 in back wages and $89,886.50 in civil money penalties).

Q: What is a consent judgment?

A: A consent judgment is a court order entered based on the parties’ agreement. It is binding and enforceable even though it resolves the case without a trial.

Q: Did the court’s order include future compliance requirements?

A: Yes. The order included a permanent injunction designed to prevent future violations and require compliance going forward.

If you believe you were denied earned wages, charged improper work-related fees, or not provided required wage information, the employment law attorneys at Blumenthal Nordrehaug Bhowmik De Blouw LLP can help you understand your options. Contact the firm’s offices in Los Angeles, San Diego, San Francisco, Sacramento, Riverside, or Chicago to discuss potential recovery of unpaid wages and legal accountability.