Coronel v. Pinnacle Agriculture Distribution, Inc.

The California Supreme Court denied review of an appellate court judgment in favor of Simplot in a case called Coronel v. Pinnacle Agriculture Distribution, Inc. (Coronel). The California Fourth District Court of Appeal held, in an unpublished opinion, that a judgment in a prior class action alleging unpaid wages and inaccurate pay records barred a subsequent putative class action for unpaid wages and inaccurate pay records as a result of a release in the prior class action, even though plaintiff argued the subsequent class action encompassed claims broader than the settlement agreement and judgment in the prior class action. 

In 2017, a former employee of Pinnacle Agriculture (acquired by Simplot in 2020), Damian Reyes, filed a class-action lawsuit alleging unpaid wages and inaccurate payroll records, as well as claims under California's Private Attorneys General Act (PAGA) (Reyes). The Reyes class action was resolved, including through settlement agreements with the class members.

While Reyes was pending, the instant plaintiff, Juvenal Coronel, filed another action. The Coronel class sought to recover for the same claims asserted in Reyes and to further expand the scope of those claims, adding new claims based on different labor code violations, which were not asserted in Reyes. Simplot argued that the release and judgment obtained in the Reyes class action barred all claims asserted in Coronel, even those for violations of different California Labor Code provisions. Specifically, it was argued, in California, claim preclusion bars subsequent suits between parties involving the same "primary right," and Coronel involved the same "primary right" as Reyes: the right to be paid for time worked. The trial court agreed and dismissed the Coronel case in its entirety. The appellate court affirmed in an unpublished opinion, and the Supreme Court denied review. Although unpublished, the result supports the position that any class-action judgment for unpaid wages will likely bar a subsequent suit between a class member and the same defendant for other unpaid wages, thereby preventing class members from getting a "second bite at the apple" by adding new theories of liability to class claims which have already been resolved—an important win for California employers.