Employee class decertified on inadequate analysis

A federal appeals court has decertified a class of employees of a golf management firm, stating the lower district court had failed to conduct a proper analysis.

Dallas-based Century Golf Partners Management L.P. is being charged with violations of the federal Fair Labor Standards Act and New York labor law at New York catering facilities operated by the firm, according to Tuesday’s ruling by the 5th U.S. Circuit Court of Appeals in New Orleans in Jillian Izzio et al. v. Century Golf Partners Management L.P., Anthony Metzger.

It is one of several cases filed against Century Golf, according to the ruling. The U.S. District Court in Dallas certified a class in the case and approved a settlement. An objection was filed to the class certification, including by a plaintiff who has filed separate litigation against the firm, according to court papers.

The U.S. Supreme Court requires district courts to analyze four prerequisites for class certification: numerosity, commonality, typicality and adequacy of representation, said a unanimous three-judge panel of the 5th Circuit.

Appellants “argue that class certification was improper because the district court did not conduct an adequate analysis,” said the ruling. They contend the district court “conducted no analysis, much less a rigorous analysis,” it said.

“Having reviewed the record and the briefs, we agree with appellants,” said the panel in vacating the class certification order and remanding the case.