Hernandez v. Overhill Farms
Plaintiffs are former employees of Overhill Farms, Inc. (Overhill), a company that manufactures frozen food products for sale to distributors and wholesalers. Plaintiffs asserted wage and hour claims against Overhill on behalf of a purported class made up of Overhill’s nonexempt (hourly) employees who worked in identified departments between July 1, 2005, and the present.
The trial court denied plaintiffs’ motion for class certification, concluding that the named plaintiffs were not adequate class representatives and individual issues predominated over common ones. Plaintiffs appeal, contending that the trial court applied incorrect legal standards and substantial evidence did not support its conclusions.
Our review of a denial of a motion for class certification is limited—we must affirm an order supported by substantial evidence unless the trial court used improper criteria or made erroneous legal assumptions. Further, we defer to the trial court’s credibility determinations. Because we find that, in light of the trial court’s credibility determinations, substantial evidence supported the trial court’s conclusion that individual issues predominated over common ones, we affirm.
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