SAN FRANCISCO — Minor league professional baseball players
in several states, including Pennsylvania, lost their bid for certification of
a multi-state class in an attempt to seek compensation for baseball-related activities
performed outside of the regular season.
U.S. Magistrate Judge Joseph Spero of the Northern
District of California denied the players’ motion for class certification in a
July 21 ruling and granted the teams’ request for decertification. The players’
request for class certification asserted claims under the Fair Labor Standards
The players in the proposed class - who played for minor
league teams in California, Florida, Arizona, North Carolina, New York,
Pennsylvania, Maryland and Oregon - argued that they should be paid more for
spring training, instructional league play, offseason workouts and other
team-mandated activities that did not fall within the regular season.
Proposed class representatives for the Pennsylvania class
included Tim Pahuta, Kris Watts and Lauren Gagnier.
The players told the court that class certification was
warranted because Major League Baseball and the teams used universal contracts
and policies. However, the teams contended that every player’s offseason
training circumstances were different, so the class should not be certified.
“I think the court looked at the complexity of the facts it
was going to have to address with regard to the offseason workout analysis,” J.
William Manuel, a partner at Bradley Arant Boult Cummings LLP, told the Pennsylvania Record.
“Since each team,
and, in some cases, each individual player was going to be required to present
specific facts related to what they were alleging were off-the-clock work, the court
couldn’t find a way to make it easy to handle in a uniform fashion.”
The court agreed with the clubs’ argument that the offseason
activities were too widely varied from player to player. Spero also said it was
not easy to tell which offseason activities could be classified as work and
which could not.
“Overall, it was the wide variety of offseason activities
that essentially doomed this as a class action,” Manuel said. “If the minor
leagues had a more uniform offseason workout schedule, it might have worked.”
The players can still proceed with individual lawsuits
following Spero’s ruling. However, Manuel said he would guess that players may
try to certify another class in a different forum.
“It is going to be difficult in light of this long and
detailed opinion, but they may be able to better craft an argument in another
court if they can convince the judge that there is a way to effectively connect
all the claims,” Manuel said. “It will be a long shot, though.”
If the players don’t try to certify a class in another
forum, Manuel said, they can still proceed with smaller collective actions,
such as an action filed by all of the players of one minor league team during a
specific time frame.
“With that limited scope, a court may be more willing to
lump several players together,” Manuel said.
On May 20, 2015, the players filed a second amended consolidated
complaint for violations of federal and state wage and hours Laws. On the same
day, the court ruled on challenges to personal jurisdiction by 11 Major League
Baseball Clubs, ruling that the activities of the Pittsburgh Pirates, the New
York Yankees and the Detroit Tigers were sufficient to establish the existence
of personal jurisdiction over them in California.
In that May 20, 2015 order, Spero dismissed the remaining
eight defendants for lack of personal jurisdiction. Those eight clubs included the
Philadelphia Phillies, the Atlanta Braves, the Chicago White Sox, the Tampa Bay
Rays, the Washington Nationals, the Boston Red Sox, the Baltimore Orioles and
the Cleveland Indians.