Pa. minor league baseball players lose bid for class action certification

By Carrie Salls | Aug 4, 2016

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 Act.

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.

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