In Myers v. Raley's, ___ Cal.App.5th ___ (Mar. 12, 2019), the Court of Appeal (Third Appellate District) reversed an order denying class certification of certain wage and hour claims. The trial court failed to adequately explain its finding that common questions did not predominate, inhibiting appellate review and requiring reversal.
The panel directed the trial court to issue a new statement of decision adequately explaining its reasoning and addressing new authority post-dating its original order:
Our review of the trial court’s denial of class certification is governed by a unique standard of review requiring us to examine the trial court’s reasons, not the propriety of the outcome. Because the trial court’s cursory finding renders our task impossible and because cases decided after the court’s ruling expose the dangers of employing the wrong legal criteria, asking the wrong questions, or inflating the significance of the opposing parties’ evidence, we must remand this case to the trial court for reconsideration in light of Ayala and Jones and for a statement of reasons to ensure the court has not employed improper criteria or relied on erroneous legal assumptions.
Slip op. at 2 (citing Ayala v. Antelope Valley Newspapers, Inc., 59 Cal.4th 522 (2014); Jones v. Farmers Ins. Exchange (2013) 221 Cal.App.4th 986 (2013)).
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