Case: Knox v. Westly

2:05-cv-02198 | U.S. District Court for the Eastern District of California

Filed Date: Nov. 1, 2005

Closed Date: 2014

Clearinghouse coding complete

Case Summary

On November 1, 2005, non-union employees who paid compulsory union fees, filed this class-action lawsuit under 42 U.S.C. § 1983, against the California State Employees Association (CSEA) in the Eastern District of California. The plaintiffs, represented by the National Right to Work Legal Defense Foundation and private counsel, sought immediate injunctive and declaratory relief, and damages, claiming that the defendant violated public employees' rights, privileges, and immunities under the Firs…

On November 1, 2005, non-union employees who paid compulsory union fees, filed this class-action lawsuit under 42 U.S.C. § 1983, against the California State Employees Association (CSEA) in the Eastern District of California. The plaintiffs, represented by the National Right to Work Legal Defense Foundation and private counsel, sought immediate injunctive and declaratory relief, and damages, claiming that the defendant violated public employees' rights, privileges, and immunities under the First and Fourteenth Amendments to the United States Constitution. Specifically, the plaintiffs claimed that the defendant violated the constitutional safeguards compelled by Chicago Teachers Union v. Hudson, 475 U.S. 292 (1986) by failing to properly notify employees of a temporary dues increase to fund political activities through the “Emergency Temporary Assessment to Build a Political Fight Back Fund.”

On November 2, 2005, the plaintiffs filed a motion to set a date for a preliminary injunction hearing and for a temporary restraining order to stop the defendant from taking money from the plaintiffs' fees for political use and to place that money into a separate escrow account. Judge Morrison C. England granted the plaintiffs' motion for the temporary restraining order on November 8, 2005, recognizing that the plaintiffs would suffer irreparable harm if the restraining order was not granted, and granted a hearing on their motion for preliminary injunction. 2005 WL 3031622. Because Judge England granted the temporary restraining order, he denied further relief through a preliminary injunction on November 8, 2005. 2005 WL 3031622.

On October 31, 2006, Judge England granted the plaintiffs' class certification request, deeming the plaintiffs adequate representation of the class. The certified class consisted of individuals who pay compulsory fees to CSEA who are not members and who have, at one time or another, specifically objected to the use of their agency fees for politics or other non-bargaining activities. The plaintiffs represented two classes of nonunion employees: those who objected to the Union's notification to deduct money for non-bargaining purposes and those who did not.

On February 12, 2007, Judge England denied the defendant’s motion for summary judgment filed on September 29, 2006 on the grounds that CSEA’s evidence of its notification and procedure of using the non-members fees for political purposes did not meet the constitutional safeguards laid out by Hudson, and therefore did not warrant judgment as a matter of law. 2007 WL 516263.

The plaintiffs’ filed a motion for summary judgment on July 13, 2007, arguing that the evidence proved the defendant failed to comply with the constitutional standards of Hudson. The defendant filed a motion for partial summary judgment on July 17, 2007, alleging that the class of plaintiffs who did not object to the use of their money for political purposes should be precluded from bringing suit because they failed to make a timely objection to the defendant’s notice of this procedure, which constituted, as a matter of law, their consent to the procedure.

 

Judge England denied the defendant’s partial motion for summary judgment as to the non-objector class, but granted the plaintiffs’ summary judgment motion on March 27, 2008. Judge England stated that the first notice the defendant’s referred to could not possibly have supplied the essential information with which nonmembers could make an informed choice of whether or not to object to the deduction. The Union was ordered to issue a proper notice as to the deductions for political purposes, with a renewed opportunity for nonmembers to object to paying the non-chargeable portion of the fee and to issue appropriate refund with interest. Judge England ordered this second notice not because the first notice could not conceivably cover any assessment or dues increase, but because the actual notice in this case was inadequate to provide the essential information regarding the specific deduction for political purposes. 2005 WL 3031622.

The defendant submitted its amended notice of appeal of the District Court’s denial of summary adjudication as to the class of non-objectors on August 26, 2008. The Ninth Circuit (David R. Thompson, Sidney R. Thomas, Clifford Wallace) reversed the District Court’s ruling on the motions for summary judgment on December 10, 2010, concluding that the union’s notification complied with the Hudson procedural requirements. 628 F.3d 1115.

Back in District Court, on February 15, 2011 Judge England ordered, in accordance with the Ninth Circuit Court of Appeals decision, the denial of the plaintiffs’ motion for summary judgment, reversal and denial of the defendant’s partial motion for summary judgment, the granting of the defendant’s motion for summary judgment, and the reversal of the award of nominal damages to the plaintiff.

However, the plaintiffs appealed the Ninth Circuit decision and the Supreme Court granted certiorari on June 27, 2011. Writing for the majority, Justice Alito reversed the Ninth Circuit decision and remanded the case back to the Ninth Circuit on June 21, 2012. Justice Alito held that Hudson requires that any fee-collection procedure be tailored to minimize the infringement on First Amendment rights and the defendant in this case failed to meet this standard. The notice was insufficient and charging nonmembers fees to be used for “electoral purposes,” even if they would be paid back had they chosen to opt out after the relevant period, was a violation of the First Amendment. 567 U.S. 298.

On remand, the Ninth Circuit vacated the District Court opinion and remanded the case back to the District Court for further proceedings.

On December 4, 2012 the district court entered judgment for the plaintiffs and ordered the defendant to refund the plaintiffs all money extracted from the assessment period with interest, as well as pay nominal damages in the amount of one dollar within 120 days of the order. The defendant was required to check in with the court every thirty days to update on its progress.

The plaintiffs’ moved for attorney’s fees on January 2, 2013, which Judge England granted on June 5, 2013. The plaintiffs were awarded $ 1,201,176.00 in attorney’s fees and $15,412.93 in expenses. A supplemental motion for attorney’s fees was denied by Judge England on April 16, 2014. The case is now closed.

 

Summary Authors

Jenna Chai (6/14/2010)

Mackenzie Walz (11/17/2017)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/4158337/parties/knox-v-westly/


Judge(s)

Alito, Samuel A. Jr. (District of Columbia)

Attorney for Plaintiff

Burlingham, Steven R. (California)

Attorney for Defendant

Berzon, Stephen P. (California)

Chapman, Ronald W. (California)

Demain, Jeffrey B. (California)

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Documents in the Clearinghouse

Document

08-16645

Docket [PACER]

U. S. Court of Appeals for the Ninth Circuit

Aug. 6, 2014

Aug. 6, 2014

Docket

2:05-cv-02198

Docket

Aug. 7, 2014

Aug. 7, 2014

Docket

2:05-cv-02198

Plaintiff's Verified Class Action Complaint

U. S. Court of Appeals for the Ninth Circuit

Nov. 1, 2005

Nov. 1, 2005

Complaint
6

2:05-cv-02198

Plaintiff's Memorandum of Points and Authorities in Support of Their Ex Parte Application for a Temporary Restraining Order and/or a Preliminary Injunction

Nov. 2, 2005

Nov. 2, 2005

Pleading / Motion / Brief

2:05-cv-02198

Opposition to Plaintiff's Motion for Preliminary Injunction

U. S. Court of Appeals for the Ninth Circuit

Nov. 4, 2005

Nov. 4, 2005

Pleading / Motion / Brief
39

2:05-cv-02198

Memorandum of Points and Authorities in Support of SEIU, Local 1000's Motion to Dismiss and for Partial Summary Judgment

Feb. 17, 2006

Feb. 17, 2006

Pleading / Motion / Brief
38

2:05-cv-02198

SEIU, Local 1000's Notice of Motion and Motion to Dismiss and for Partial Summary Judgment

Feb. 17, 2006

Feb. 17, 2006

Pleading / Motion / Brief
62

2:05-cv-02198

Plaintiff's Corrected Second Revised Notice of Motion & Renewed Motion for Class Certification

Sept. 22, 2006

Sept. 22, 2006

Notice Letter
63

2:05-cv-02198

SEIU, Local 1000's Notice of Motion for Summary Judgment

Sept. 28, 2006

Sept. 28, 2006

Notice Letter
81

2:05-cv-02198

Order Granting Plaintiffs' Motion for Class Certification

Oct. 31, 2006

Oct. 31, 2006

Order/Opinion

Docket

See docket on RECAP: https://www.courtlistener.com/docket/4158337/knox-v-westly/

Last updated March 14, 2024, 3:14 a.m.

ECF Number Description Date Link Date / Link
1

VERIFIED CLASS ACTION COMPLAINT against all defendants, filed by Plaintiffs. (Attachments: # 1 Civil Cover Sheet)(Krueger, M) (Entered: 11/01/2005)

1 Civil Cover Sheet

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Nov. 1, 2005

Nov. 1, 2005

RECAP
2

SUMMONS ISSUED as to *Steve Westly, California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC* with answer to complaint due within *20* days. Attorney *Steven R. Burlingham* *Gary, Till and Burlingham* *5330 Madison Avenue, Suite F* *Sacramento, CA 95841*. (Krueger, M) (Entered: 11/01/2005)

Nov. 1, 2005

Nov. 1, 2005

PACER
3

CIVIL NEW CASE DOCUMENTS ISSUED; (Attachments: # 1 Consent Forms # 2 VDRP Forms) (Krueger, M) (Entered: 11/01/2005)

1 Consent Forms

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2 VDRP Forms

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Nov. 1, 2005

Nov. 1, 2005

PACER
4

PRO HAC VICE APPLICATION and PROPOSED ORDER by Plaintiffs for attorney W. James Young to appear Pro Hac Vice for Plaintiffs. (Krueger, M) (Entered: 11/01/2005)

Nov. 1, 2005

Nov. 1, 2005

PACER
5

PRO HAC VICE ORDER signed by Judge Morrison C. England Jr. on 11/02/05: Added attorney W. James Young for Patrick Johnson; Jon Jumper; R. Paul Ricker; Dianne Knox; William L. Blaylock; Robert A. Conover; Edward L. Dobrowolski, Jr; Karyn Gil and Thomas Jacob Hass. (Warren, P) (Entered: 11/02/2005)

Nov. 2, 2005

Nov. 2, 2005

PACER
11

MINUTES for proceedings held before Judge Morrison C. England Jr.: IN COURT HEARING held on 11/2/2005. Plantiffs gave opening argument. Defendants request for continunace of TRO Hearing. Plaintiffs gave rebuttal. Defendants responded. For the reasons given, the TRO is granted. Preliminary Injunction set for Friday, November 4, 2005 at 10:00 AM in Courtroom 3 (MCE) before Judge Morrison C. England Jr.. Oppositions due not later than 2 p.m. on Thursday, November 3, 2005. Replies due not later than 4:30 p.m. on Thursday, November 3, 2005.Plaintiffs Counsel James Young present. Defendants Counsel Jonathan Weissglass and Jeffrey Demain (appearing by telephone) present. Court Reporter: Diane Shepard. (Souvannarath, A) (Entered: 11/03/2005)

Nov. 2, 2005

Nov. 2, 2005

PACER
6

Ex Parte MOTION for TEMPORARY RESTRAINING ORDER and/or Preliminary Injunction by Karyn Gil, Thomas Jacob Hass, Patrick Johnson, Jon Jumper, R. Paul Ricker, Dianne Knox, William L. Blaylock, Robert A. Conover, Edward L. Dobrowolski, Jr. (Attachments: # 1 Declaration # 2 Exhibit A # 3 Memorandum #(4) Proposed Order granting TRO #(5) Proposed Order granting Preliminary Injunction)(Burlingham, Steven) Modified on 11/3/2005 (Girgis, C). (Entered: 11/02/2005)

1 Declaration of W. James Young re: Irreparable Harm

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2 Exhibit A to Young Declaration

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3 Memorandum in Support of Motion

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4 Proposed Order granting TRO

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5 Proposed Order granting Preliminary Injunction

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Nov. 2, 2005

Nov. 2, 2005

PACER
7

ORDER granting 6 Motion for Temporary Restraining Order. Signed by Judge Morrison C. England, Jr. on 11/3/2005.(Deutsch, S) (Entered: 11/03/2005)

Nov. 3, 2005

Nov. 3, 2005

RECAP
12

MEMORANDUM/RESPONSE in OPPOSITION to Motion for Preliminary Injunction. (Attachments: # 1 Exhibit)(Demain, Jeffrey) Modified on 11/7/2005 (Krueger, M). (Entered: 11/03/2005)

1 Exhibit

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Nov. 3, 2005

Nov. 3, 2005

PACER
8

DECLARATION of Jeffrey B. Demain in OPPOSITION to 6 Ex Parte MOTION for TEMPORARY RESTRAINING ORDER and/or Preliminary Injunction. (Demain, Jeffrey) Modified on 11/7/2005 (Krueger, M). (Entered: 11/03/2005)

Nov. 3, 2005

Nov. 3, 2005

PACER
13

CERTIFICATE of SERVICE by California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC re 8, 9, 10, 12 Memorandum/Response in Opposition to Motion (Demain, Jeffrey) (Entered: 11/03/2005)

Nov. 3, 2005

Nov. 3, 2005

PACER
9

DECLARATION of Cathy Hackett in OPPOSITION to 6 Ex Parte MOTION for TEMPORARY RESTRAINING ORDER and/or Preliminary Injunction.(Attachments: # 1 Exhibit A)(Demain, Jeffrey) Modified on 11/7/2005 (Krueger, M). (Entered: 11/03/2005)

1 Exhibit A

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Nov. 3, 2005

Nov. 3, 2005

PACER
14

MEMORANDUM/RESPONSE in OPPOSITION to Motion for Preliminary Injunction. (Woods, Douglas) (Entered: 11/03/2005)

Nov. 3, 2005

Nov. 3, 2005

PACER
10

DECLARATION of Lee King in OPPOSITION to 6 Ex Parte MOTION for TEMPORARY RESTRAINING ORDER and/or Preliminary Injunction. (Demain, Jeffrey) Modified on 11/7/2005 (Krueger, M). (Entered: 11/03/2005)

Nov. 3, 2005

Nov. 3, 2005

PACER
15

REPLY to Defendants' Oppositions to Motion for TRO and/or Preliminary Injunction by Plaintiffs. (Burlingham, Steven) Modified on 11/7/2005 (Krueger, M). (Entered: 11/03/2005)

Nov. 3, 2005

Nov. 3, 2005

PACER
16

CORRECTED CERTIFICATE of SERVICE of 15 Reply to Defendants' Oppositions by Plaintiffs. (Burlingham, Steven) Modified on 11/7/2005 (Krueger, M). (Entered: 11/03/2005)

Nov. 3, 2005

Nov. 3, 2005

PACER
17

MOTION for CLASS CERTIFICATION by Plaintiffs. Motion Hearing set for 12/5/2005 at 09:00 AM in Courtroom 3 (MCE) before Judge Morrison C. England Jr. (Attachments: # 1 Memorandum of Points and Authorities # 2 Declaration of W. James Young)(Burlingham, Steven) Modified on 11/7/2005 (Krueger, M). (Entered: 11/03/2005)

1 Memorandum of Points and Authorities

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2 Declaration of W. James Young

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Nov. 3, 2005

Nov. 3, 2005

PACER
18

DECLARATION of Robert A. Conover in Support of 6 Ex Parte MOTION for TEMPORARY RESTRAINING ORDER and/or Preliminary Injunction. (Burlingham, Steven) (Entered: 11/04/2005)

Nov. 4, 2005

Nov. 4, 2005

PACER
19

CERTIFICATE of SERVICE by Karyn Gil, Thomas Jacob Hass, Patrick Johnson, Jon Jumper, R. Paul Ricker, Dianne Knox, William L. Blaylock, Robert A. Conover, Edward L. Dobrowolski, Jr re 18 Conover Declaration (Burlingham, Steven) (Entered: 11/04/2005)

Nov. 4, 2005

Nov. 4, 2005

PACER
20

MINUTES for proceedings held before Judge Morrison C. England Jr.: IN COURT HEARING held on 11/4/2005 regarding Preliminary Injunction and 6 MOTION for TEMPORARY RESTRAINING ORDER. The court addresses counsel regarding member dues. Court also addresses letters dated 06-30-05 and 08-31-05 and the Hudson notice. Arguments presented by both parties. Mr. Demain, counsel for the Union dfts, requests the court to enter an order returning the $525,000 back to the Union should the preliminary injunction not issue. The Union dfts also request that the current motion to certify class scheduled for hearing on 12/5/05 be continued to a future date to allow time for discovery prior to the hearing. Counsel for dft Steve Westly, Mr. Woods, explains to the Court how the system at the Controller's Office works with regards to the special assessment and withholding. For the reasons given by the Court, the preliminary injunction is denied. Plaintiff's counsel, Mr. Young, requests that the injunction be ordered as to the named Plaintiffs in this action. The Union will return money to the invdividual fee members. Court further orders that the money in the amount of $525,000 be released forthwith. Parties shall discuss the hearing date on the motion to certify class and advise the courtroom deputy of same. Court order will follow. Plaintiffs Counsel W. James Young present. Defendants Counsel Stephen P Berzon and Jeffrey Demain for Union defendants. Douglas Woods for defendant Steve Westly. Court Reporter: Diane Shepard. (Souvannarath, A) Modified on 11/7/2005 (Krueger, M). (Entered: 11/04/2005)

Nov. 4, 2005

Nov. 4, 2005

PACER
21

MEMORANDUM AND ORDER signed by Judge Morrison C. England Jr. on 11/4/05 ORDERING the funds in the amount of $525,000.00 which were depositedby SEIU, Local 1000, into the account of the US District Court pursuant to a TRO, entered by this Court on 11/3/05, are to be returned to SEIU forthwith. (cc: Court's Financial Department). (Krueger, M) (Entered: 11/08/2005)

Nov. 8, 2005

Nov. 8, 2005

RECAP
22

TRANSCRIPT of Motion for TRO Hearing held on 11/2/05 before Judge Morrison C. England, Jr. Court Reporter: Diane J. Shepard. (Krueger, M) Modified to add image on 7/16/2009 (Waggoner, D). (Entered: 11/09/2005)

Nov. 9, 2005

Nov. 9, 2005

PACER
23

ORDER signed by Judge Morrison C. England Jr. on 11/8/05 ORDERNG Plaintiffs Motion for Preliminary Injunction 6 DENIED. (Krueger, M) (Entered: 11/09/2005)

Nov. 9, 2005

Nov. 9, 2005

RECAP
24

STIPULATION for Extension of Time until 12/21/05 to Answer Complaint by California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC. (Demain, Jeffrey) Modified on 11/16/2005 (Krueger, M). (Entered: 11/15/2005)

Nov. 15, 2005

Nov. 15, 2005

PACER
25

CERTIFICATE of SERVICE by California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC re 24 Stipulation (Demain, Jeffrey) (Entered: 11/15/2005)

Nov. 15, 2005

Nov. 15, 2005

PACER
26

CERTIFICATE of SERVICE by Karyn Gil, Thomas Jacob Hass, Patrick Johnson, Jon Jumper, R. Paul Ricker, Dianne Knox, William L. Blaylock, Robert A. Conover, Edward L. Dobrowolski, Jr re 3 Civil New Case Documents for MCE (Young, W.) (Entered: 11/16/2005)

Nov. 16, 2005

Nov. 16, 2005

PACER
27

SUMMONS RETURNED EXECUTED by Plaintiffs, Steve Westly served on 11/2/2005, answer due 11/22/2005; California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC served on 11/2/2005, answer due 11/22/2005. (Young, W.) Modified on 11/21/2005 (Krueger, M). (Entered: 11/18/2005)

Nov. 18, 2005

Nov. 18, 2005

PACER
28

ANSWER to COMPLAINT by CA State Employees Assoc, Local 1000, Service Employees Int'l Union, AFL-CIO-CLC (Demain, Jeffrey. Modified on 12/21/2005 (Kastilahn, A). (Entered: 12/21/2005)

Dec. 21, 2005

Dec. 21, 2005

PACER
29

ANSWER to COMPLAINT by Steve Westly.(Woods, Douglas) Modified on 12/22/2005 (Krueger, M). (Entered: 12/21/2005)

Dec. 21, 2005

Dec. 21, 2005

PACER
30

JOINT STATUS REPORT by Karyn Gil, Thomas Jacob Hass, Patrick Johnson, Jon Jumper, R. Paul Ricker, California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC, Dianne Knox, William L. Blaylock, Robert A. Conover, Edward L. Dobrowolski, Jr. (Young, W.) (Entered: 01/03/2006)

Jan. 3, 2006

Jan. 3, 2006

PACER
31

SUPPLEMENTAL STATUS REPORT by Steve Westly. (Woods, Douglas) (Entered: 01/05/2006)

Jan. 5, 2006

Jan. 5, 2006

PACER
32

PRETRIAL (STATUS) SCHEDULING ORDER signed by Judge Morrison C. England Jr. on 1/11/06: Designation of Expert Witnesses due by 5/14/2007. Discovery due by 3/12/2007. Dispositive Motions shall be due by 8/13/2007. Final Pretrial Conference set for 10/29/2007 at 01:30 PM, and the parties shall file a Joint Pretrial Statement by 10/15/2007. Court Trial set for 12/12/2007 at 09:00 AM in Courtroom 3 (MCE) before Judge Morrison C. England Jr. (Krueger, M) (Entered: 01/12/2006)

Jan. 12, 2006

Jan. 12, 2006

PACER
33

LIMITED OBJECTION to the 32 Pretrial (Status) Scheduling Order by Defendant California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC. (Demain, Jeffrey) Modified on 1/18/2006 (Krueger, M). (Entered: 01/17/2006)

Jan. 17, 2006

Jan. 17, 2006

PACER
34

AMENDED PRETRIAL (STATUS) SCHEDULING ORDER signed by Judge Morrison C. England Jr. on 1/20/06: Designation of Expert Witnesses due by 5/14/2007. Discovery due by 3/12/2007. Dispositive Motions shall be heard by 8/13/2007. Final Pretrial Conference set for 10/29/2007 at 01:30 PM, with a Joint Pretrial Statement due by 10/15/2007. Court Trial set for 12/12/2007 at 09:00 AM in Courtroom 3 (MCE) before Judge Morrison C. England Jr. (Krueger, M) (Entered: 01/23/2006)

Jan. 23, 2006

Jan. 23, 2006

PACER
35

NOTICE of HEARING by all plaintiffs re 17 MOTION to CERTIFY CLASS and Appoint Class Counsel. Motion Hearing Set for 3/20/06 at 9:00 AM in Courtroom 3 (MCE) before Judge Morrison C. England, Jr. (Young, W.) Modified on 1/25/2006 (Krueger, M). (Entered: 01/23/2006)

Jan. 23, 2006

Jan. 23, 2006

PACER
36

REQUEST for Continuance of Hearing on Plaintiffs' Motion for Class Certification by California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC. (Attachments: # 1 Declaration # 2 Proposed Order)(Demain, Jeffrey) (Entered: 01/24/2006)

1 Declaration

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2 Proposed Order

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Jan. 24, 2006

Jan. 24, 2006

PACER
37

ORDER signed by Judge Morrison C. England Jr. on 1/25/06 ORDERING that the hearing date of 3/20/06 currently set for Plaintiffs' Motion for Class Certification 17 is hereby VACATED. Pltfs may re-notice their Motion for Class Certification after the Court resolves the Union's Motion to Dismiss. (Krueger, M) (Entered: 01/26/2006)

Jan. 26, 2006

Jan. 26, 2006

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38

MOTION to DISMISS and for Partial Summary Judgment by California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC. Motion Hearing set for 3/20/2007 at 09:00 AM in Courtroom 3 (MCE) before Judge Morrison C. England Jr.. (Thoreen, Peder) (Entered: 02/17/2006)

Feb. 17, 2006

Feb. 17, 2006

PACER
39

MEMORANDUM/RESPONSE in SUPPORT re 38 MOTION to DISMISS and for Partial Summary Judgment. (Thoreen, Peder) (Entered: 02/17/2006)

Feb. 17, 2006

Feb. 17, 2006

PACER
40

STATEMENT of Undisputed Facts in Support of SEIU Local 1000's Motion to Dismiss and for Partial Summary Judgment by Defendant California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC re 38 MOTION to DISMISS and for Partial Summary Judgment. (Thoreen, Peder) (Entered: 02/17/2006)

Feb. 17, 2006

Feb. 17, 2006

PACER
41

DECLARATION of Jeffrey B. Demain in SUPPORT OF re 38 MOTION to DISMISS and for Partial Summary Judgment. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C)(Thoreen, Peder) (Entered: 02/17/2006)

1 Exhibit A

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2 Exhibit B

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3 Exhibit C

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Feb. 17, 2006

Feb. 17, 2006

PACER
42

NOTICE OF LODGING DOCUMENT IN PAPER: Deposition Transcript of December 12, 2005 Deposition of R. Paul Ricker pursuant to Local Rule 5-133(j) by Defendant. (Thoreen, Peder) (Document Routed to the Fileroom). Modified on 2/21/2006 (Krueger, M). (Entered: 02/21/2006)

Feb. 21, 2006

Feb. 21, 2006

PACER
43

STIPULATION AND PROPOSED ORDER of voluntary dismissal of pltf R. Paul Ricker and for withdrawal of pending motions by R. Paul Ricker (Young, W.) Modified on 3/6/2006 (Reader, L). (Entered: 03/06/2006)

March 6, 2006

March 6, 2006

PACER
44

STIPULATION and ORDER 43 signed by Judge Morrison C. England Jr. on 3/8/06 GRANTING Voluntary Dismissal of Pltf R. Paul Ricker pursuant to FRCP 41(a)(1). Pltfs' Motion to Certify Class 17, and Defendants Motion to Dismiss and for Partial Summary Judgment 38 are hereby WITHDRAWN.(Krueger, M) (Entered: 03/09/2006)

March 9, 2006

March 9, 2006

RECAP
45

RENEWED MOTION to CERTIFY CLASS and Class Counsel by Plaintiffs. Motion Hearing set for 5/1/2006 at 09:00 AM in Courtroom 3 (MCE) before Judge Morrison C. England Jr. (Attachments: # 1 Memorandum # 2 Declaration of W. James Young)(Young, W.) Modified on 4/3/2006 (Krueger, M). (Entered: 03/31/2006)

1 Memorandum

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2 Declaration of W. James Young

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March 31, 2006

March 31, 2006

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46

NOTICE by all plaintiffs re 45 PLAINTIFF(S) MOTION to CERTIFY CLASS and Class Counsel Revised Notice of Motion (Young, W.) (Entered: 04/12/2006)

April 12, 2006

April 12, 2006

PACER
47

REQUEST for Continuance of Hearing on Plaintiffs' Motion for Class Certification by California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC. (Thoreen, Peder) (Entered: 04/13/2006)

April 13, 2006

April 13, 2006

PACER
48

DECLARATION of Jeffrey B. Demain in Support of 47 Request for Continuance of Hearing. (Thoreen, Peder) Modified on 4/14/2006 (Donati, J). (Entered: 04/13/2006)

April 13, 2006

April 13, 2006

PACER
49

PROPOSED ORDER for 47 Request for Continuance of Hearing. (Thoreen, Peder) Modified on 4/14/2006 (Donati, J). (Entered: 04/13/2006)

April 13, 2006

April 13, 2006

PACER
50

MOTION for Partial JUDGMENT by California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC. Motion Hearing set for 6/5/2006 at 09:00 AM in Courtroom 3 (MCE) before Judge Morrison C. England Jr.. (Thoreen, Peder) Modified on 4/14/2006 (Donati, J). (Entered: 04/13/2006)

April 13, 2006

April 13, 2006

PACER
51

MEMORANDUM of POINTS and AUTHORITIES in Support of 50 Motion for Partial Judgment by California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC. (Thoreen, Peder) Modified on 4/14/2006 (Donati, J). (Entered: 04/13/2006)

April 13, 2006

April 13, 2006

PACER
52

MEMORADUM AND ORDER signed by Judge Morrison C. England Jr. on 4/20/06 ORDERING Defendant's Motion for Continuance is GRANTED. Plaintiffs' Motion for Class Certification 45 is CONTINUED to 8/7/2006 at 09:00 AM in Courtroom 3 (MCE) before Judge Morrison C. England Jr. (Krueger, M) (Entered: 04/20/2006)

April 20, 2006

April 20, 2006

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53

MEMORANDUM/RESPONSE in Opposition to 50 Motion for Partial Judgment by Plaintiffs. (Young, W.) Modified on 5/22/2006 (Donati, J). (Entered: 05/19/2006)

May 19, 2006

May 19, 2006

PACER
54

STATEMENT of NON-OPPOSITION to MOTION for PARTIAL JUDGMENT on the Pleadings. (Woods, Douglas) Modified on 5/25/2006 (Krueger, M). (Entered: 05/24/2006)

May 24, 2006

May 24, 2006

PACER
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REPLY in SUPPORT of 50 PARTIAL JUDGMENT on the Pleadings by California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC. (Thoreen, Peder) Modified on 5/30/2006 (Krueger, M). (Entered: 05/26/2006)

May 26, 2006

May 26, 2006

PACER
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MINUTE ORDER: (TEXT ONLY ENTRY) The Defendants' 50 Motion for for Partial Judgment, scheduled for hearing on 6/5/06, is submitted without oral argument pursuant to Local Rule 78-230(h). If the court determines that oral argument is needed, it will be scheduled at a later date.Approved by Judge Morrison C. England Jr. on 6/2/06. (Souvannarath, A) (Entered: 06/02/2006)

June 2, 2006

June 2, 2006

PACER
57

UNOPPOSED REQUEST for a continuance of hearing on pltfs' motion for class certification by California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC. (Demain, Jeffrey) Modified on 7/6/2006 (Yin, K). (Entered: 07/05/2006)

July 5, 2006

July 5, 2006

PACER
58

PROPOSED ORDER continuing pltfs' motion for class certification by California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC. (Demain, Jeffrey) Modified on 7/6/2006 (Yin, K). (Entered: 07/05/2006)

July 5, 2006

July 5, 2006

PACER
59

ORDER signed by Judge Morrison C. England Jr. on 7/11/06 ORDERING that Plaintiffs' Motion for Class Certification 45 is taken off calendar. The Court hereby VACATES the 8/7/06 hearing date set for Plaintiffs' Motion for Class Certification. Plaintiffs may re-notice their Motion for Class Certification after the Court issues an order adjudicating the Union's Rule 12(c) Motion.(Krueger, M) (Entered: 07/11/2006)

July 11, 2006

July 11, 2006

RECAP
60

ORDER signed by Judge Morrison C. England Jr. on 8/15/06 ORDERING Defendant CSEA's Motion for Partial Judgment on the Pleadings 50 is GRANTED with respect to Plaintiff Conover. (Krueger, M) (Entered: 08/16/2006)

Aug. 16, 2006

Aug. 16, 2006

RECAP
61

SECOND AMENDED RENEWED MOTION to CERTIFY CLASS by Karyn Gil, Thomas Jacob Hass, Patrick Johnson, Jon Jumper, Dianne Knox, William L. Blaylock, Edward L. Dobrowolski, Jr. Motion Hearing set for 10/16/2006 at 09:00 AM in Courtroom 3 (MCE) before Judge Morrison C. England Jr.. (Young, W.) Modified on 9/18/2006 (Donati, J). (Entered: 09/15/2006)

Sept. 15, 2006

Sept. 15, 2006

PACER
62

CORRECTED SECOND AMENDED MOTION to CERTIFY CLASS re 61 Second Amended Motion to Certify Class by Karyn Gil, Thomas Jacob Hass, Patrick Johnson, Jon Jumper, R. Paul Ricker, Dianne Knox, William L. Blaylock, Robert A. Conover, Edward L. Dobrowolski, Jr. Motion Hearing set for 10/16/2006 at 09:00 AM in Courtroom 3 (MCE) before Judge Morrison C. England Jr. (Young, W.) Modified on 9/25/2006 (Reader, L). Modified on 10/3/2006 (Krueger, M). (Entered: 09/22/2006)

Sept. 22, 2006

Sept. 22, 2006

PACER
63

MOTION for SUMMARY JUDGMENT by California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC. Motion Hearing set for 10/30/2006 at 09:00 AM in Courtroom 3 (MCE) before Judge Morrison C. England Jr. (Thoreen, Peder) Modified on 10/3/2006 (Krueger, M). (Entered: 09/29/2006)

Sept. 29, 2006

Sept. 29, 2006

PACER
64

MEMORANDUM/RESPONSE in SUPPORT re 63 MOTION for SUMMARY JUDGMENT. (Thoreen, Peder) (Entered: 09/29/2006)

Sept. 29, 2006

Sept. 29, 2006

PACER
65

STATEMENT of Undisputed Facts by Defendant California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC re 63 MOTION for SUMMARY JUDGMENT. (Thoreen, Peder) (Entered: 09/29/2006)

Sept. 29, 2006

Sept. 29, 2006

PACER
66

DECLARATION of Lee King in SUPPORT of 63 MOTION for SUMMARY JUDGMENT. (Attachments: # 1 Exhibit A # 2 Exhibit B # 3 Exhibit C)(Thoreen, Peder) Modified on 10/3/2006 (Krueger, M). (Entered: 09/29/2006)

1 Exhibit A

View on PACER

2 Exhibit B

View on PACER

3 Exhibit C

View on PACER

Sept. 29, 2006

Sept. 29, 2006

PACER
67

DECLARATION of Richard M. Graham in SUPPORT of 63 MOTION for SUMMARY JUDGMENT. (Thoreen, Peder) Modified on 10/3/2006 (Krueger, M). (Entered: 09/29/2006)

Sept. 29, 2006

Sept. 29, 2006

PACER
68

MEMORANDUM in OPPOSITION to 62 CORRECTED SECOND AMENDED MOTION to CERTIFY CLASS by CA State Employees Association. (Thoreen, Peder) Modified on 10/3/2006 (Krueger, M). (Entered: 09/29/2006)

Sept. 29, 2006

Sept. 29, 2006

PACER
69

DECLARATION of Jade San Juan in SUPPORT of 68 OPPOSITION to Corrected Second Amended Motion to Certify Class. (Thoreen, Peder) Modified on 10/3/2006 (Krueger, M). (Entered: 09/29/2006)

Sept. 29, 2006

Sept. 29, 2006

PACER
70

DECLARATION of Jeffrey B. Demain in SUPPORT of 68 OPPOSITION to Corrected Second Amended Motion to Certify Class. (Attachments: # 1 Exhibit A # 2 Exhibit B)(Thoreen, Peder) Modified on 10/3/2006 (Krueger, M). (Entered: 09/29/2006)

1 Exhibit A

View on PACER

2 Exhibit B

View on PACER

Sept. 29, 2006

Sept. 29, 2006

PACER
71

NOTICE OF LODGING DOCUMENT IN PAPER re April 7, 2006 Deposition of Robert A. Conover by California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC: Deposition Transcript Lodged with court pursuant to Local Rule 5-133(j). (Thoreen, Peder) (Received and Routed to file room) Modified on 10/2/2006 (Yin, K). (Entered: 09/29/2006)

Sept. 29, 2006

Sept. 29, 2006

PACER
72

STATEMENT of No Position on Plaintiff's Motion for Class Certification by Defendant Steve Westly. (Woods, Douglas) (Entered: 10/02/2006)

Oct. 2, 2006

Oct. 2, 2006

PACER
73

REPLY to RESPONSE to 62 Second Amended Motion to Certify Class. (Attachments: # 1 Appendix A)(Young, W.) Modified on 10/10/2006 (Donati, J). (Entered: 10/06/2006)

1 Appendix A

View on PACER

Oct. 6, 2006

Oct. 6, 2006

PACER
74

REQUEST to CONTINUE Hearing on 63 Motion for Summary Judgment by Karyn Gil, Thomas Jacob Hass, Patrick Johnson, Jon Jumper, Dianne Knox, William L. Blaylock, Robert A. Conover, Edward L. Dobrowolski, Jr. (Attachments: # 1 Proposed Order)(Young, W.) Modified on 10/10/2006 (Donati, J). Modified on 10/11/2006 (Krueger, M). (Entered: 10/06/2006)

1 Proposed Order

View on PACER

Oct. 6, 2006

Oct. 6, 2006

PACER
75

RESPONSE to 74 Motion to Continue Hearing and REQUEST to Continue Hearing on 62 Second Amended Motion to Certify Class. (Thoreen, Peder) Modified on 10/10/2006 (Donati, J). (Entered: 10/06/2006)

Oct. 6, 2006

Oct. 6, 2006

PACER
76

DECLARATION of Peder J. Thoreen in Support of 75 Response to Plaintiff's Request for a Continuance, and Separate Request for a Continuance. (Thoreen, Peder) Modified on 10/10/2006 (Donati, J). Modified on 10/11/2006 (Krueger, M). (Entered: 10/06/2006)

Oct. 6, 2006

Oct. 6, 2006

PACER
77

PROPOSED ORDER re: 74 Request to Continue Hearing and 75 Separate Request to Continue Hearing by Defendant. (Thoreen, Peder) Modified on 10/10/2006 (Donati, J). Modified on 10/11/2006 (Krueger, M). (Entered: 10/06/2006)

Oct. 6, 2006

Oct. 6, 2006

PACER
78

REPLY to RESPONSE to 74 Request to Continue by Plaintiffs. (Attachments: # 1 Proposed Order)(Young, W.) Modified on 10/10/2006 (Donati, J). Modified on 10/11/2006 (Krueger, M). (Entered: 10/10/2006)

1 Proposed Order

View on PACER

Oct. 10, 2006

Oct. 10, 2006

PACER
79

ORDER signed by Judge Morrison C. England Jr. on 10/12/06 ORDERING the Hearing on Defendant's MOTION for SUMMARY JUDGMENT 63 is CONTINUED to 12/11/2006 at 09:00 AM in Courtroom 3 (MCE) before Judge Morrison C. England Jr. Further, the Court Orders that Plaintiffs' MOTION for CLASS CERTIFICATION 62 shall remain on calendar for 10/16/06. All dates previously set forth in the PTSOregarding filing, briefing and discovery deadlines are to remain unchanged. The Court affirms those dates at this time. (Krueger, M) (Entered: 10/12/2006)

Oct. 12, 2006

Oct. 12, 2006

RECAP
80

MINUTES for proceedings held before Judge Morrison C. England Jr.: MOTION HEARING held on 10/16/2006 re 62 CORRECTED SECOND AMENDED MOTION to CERTIFY CLASS filed by Plaintiffs Patrick Johnson, Dianne Knox, William L. Blaylock, Robert A. Conover, Edward L. Dobrowolski, Jr., Karyn Gil, Thomas Jacob Hass, Jon Jumper, R. Paul Ricker. Arguments presented. Plaintiffs' counsel requests that the court amend the complaint to take out any reference to punitive damages. No objections by Defendants. Pltf's request is granted. Motion is taken under submission. Court order will follows. At the parties' request, the Court orders that the reply brief to the Dft's motion for summary judgment 63 is due on 11/17/06. Plaintiffs Counsel W. James Young present. Defendants Counsel Jeffrey Demain and Peder Thoreen for Union Dfts. Douglas Woods for Dft Controller Steve Westly. present. Court Reporter: Diane Shepard. (Souvannarath, A) (Entered: 10/16/2006)

Oct. 16, 2006

Oct. 16, 2006

PACER
81

ORDER signed by Judge Morrison C. England Jr. on 10/31/06 ORDERING Plaintiff's Motion for Class Certification 62 is GRANTED. The Court finds that the named Plfs are adequate representatives of the class of individuals who paycompulsory fees to CSEA who are not members and who have, at one time or another, specifically objected to the use of their agency fees for politics or other non-bargaining activities. The Court further finds that Pltf Conover is an adequate representative of the class of individuals who pay compulsoryfees to CSEA who are not members and who have not at any time objected to the use of their agency fees for politics or other non-bargaining activities.(Krueger, M) (Entered: 11/01/2006)

Nov. 1, 2006

Nov. 1, 2006

RECAP
82

STIPULATION and PROPOSED ORDER Proposed Stipulated Protective Order re Salary Information by California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC. (Demain, Jeffrey) (Entered: 11/15/2006)

Nov. 15, 2006

Nov. 15, 2006

PACER
83

OPPOSITION to 63 Motion for Summary Judgment (Attachments: # 1 Declaration # 2 Statement)(Young, W.) Modified on 11/16/2006 (Marciel, M). Modified on 11/17/2006 (Donati, J). (Entered: 11/16/2006)

1 Declaration

View on PACER

2 Statement

View on PACER

Nov. 16, 2006

Nov. 16, 2006

PACER
84

STIPULATION and PROTECTIVE ORDER 82 re Salary Information signed by Magistrate Judge Kimberly J. Mueller on 11/30/06. (refer to document image for details)(Marciel, M) (Entered: 11/30/2006)

Nov. 30, 2006

Nov. 30, 2006

RECAP
85

REPLY BRIEF in SUPPORT of 63 MOTION for SUMMARY JUDGMENT. (Attachments: # 1 Appendix 1 # 2 Appendix 2)(Thoreen, Peder) Modified on 12/5/2006 (Krueger, M). (Entered: 12/04/2006)

1 Appendix 1

View on PACER

2 Appendix 2

View on PACER

Dec. 4, 2006

Dec. 4, 2006

PACER
86

DECLARATION of Lee King in SUPPORT of 85 Reply Brief. (Thoreen, Peder) Modified on 12/5/2006 (Krueger, M). (Entered: 12/04/2006)

Dec. 4, 2006

Dec. 4, 2006

PACER
87

DECLARATION of Jeffrey B. Demain in SUPPORT of 85 Reply Brief. (Demain, Jeffrey) Modified on 12/5/2006 (Krueger, M). (Entered: 12/04/2006)

Dec. 4, 2006

Dec. 4, 2006

PACER
88

AMENDED REPLY BRIEF in Support of 63 Motion for Summary Judgment by California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC. (Attachments: # 1 Appendix 1 # 2 Appendix 2)(Thoreen, Peder) Modified on 12/5/2006 (Krueger, M). (Entered: 12/04/2006)

1 Appendix 1

View on PACER

2 Appendix 2

View on PACER

Dec. 4, 2006

Dec. 4, 2006

PACER
89

TRANSCRIPT of Plaintiffs' Motion to Certify Class Action held on 10/16/06 before Judge Morrison C. England, Jr. Court Reporter: Diane Shepard. (Krueger, M) Modified to add image on 7/16/2009 (Waggoner, D). (Entered: 12/08/2006)

Dec. 7, 2006

Dec. 7, 2006

PACER
90

MINUTES for proceedings held before Judge Morrison C. England Jr.: MOTION HEARING held on 12/11/2006 re 63 Motion for Summary Judgment filed by California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC. Arguments presented. Motion is taken under submission. Court order to follow. Plaintiffs Counsel W. James Young present. Defendants Counsel Jeffrey B. Demain present. Court Reporter: Diane Shepard. (Souvannarath, A) (Entered: 12/11/2006)

Dec. 11, 2006

Dec. 11, 2006

PACER
91

NOTICE of Change of Firm Name by California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC. (Demain, Jeffrey) Modified on 1/5/2007 (Krueger, M). (Entered: 01/04/2007)

Jan. 4, 2007

Jan. 4, 2007

PACER
92

MEMORANDUM and ORDER signed by Judge Morrison C. England Jr. on 2/12/07 ORDERING that CSEA's 63 Motion for Summary Judgment is DENIED. (Yin, K) (Entered: 02/12/2007)

Feb. 12, 2007

Feb. 12, 2007

RECAP
93

STIPULATION and PROPOSED ORDER to Permit Summary Judgment Motions to be Heard on 8/17/07. (Demain, Jeffrey) Modified on 5/1/2007 (Krueger, M). (Entered: 04/30/2007)

April 30, 2007

April 30, 2007

PACER
94

STIPULATION and ORDER signed by Judge Morrison C. England Jr. on 5/4/07 CONTINUING Summary Judgment Motions pursuant to the stipulation between the parties. Dispositive Motion due by 8/17/2007.(Yin, K) (Entered: 05/07/2007)

May 7, 2007

May 7, 2007

RECAP
95

DESIGNATION/DISCLOSURE of EXPERT WITNESS by California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC. (Thoreen, Peder) (Entered: 05/14/2007)

May 14, 2007

May 14, 2007

PACER
96

AMENDED DISCLOSURE of Expert Witness 95 by California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC. (Thoreen, Peder) Modified on 5/16/2007 (Duong, D). (Entered: 05/15/2007)

May 15, 2007

May 15, 2007

PACER
97

MINUTE ORDER: Due to unavailability of the Court's calendar and on the Court's own motion, the 10/29/2007 Final Pretrial Conference is advanced to 10/19/2007 at 9:00 a.m. in Courtroom 3 before the Honorable Morrison C. England, Jr. The Joint Final Pretrial Statement is to be filed not later than 10/5/2007. The 12/12/2007 Bench Trial is advanced to 12/10/2007 at 9:00 a.m. in Courtroom 3 before the Honorable Morrison C. England, Jr.Signed by Judge Morrison C. England Jr. on 5/22/2007. (Deutsch, S) (Entered: 05/22/2007)

May 22, 2007

May 22, 2007

PACER
98

[DISREGARD - AMENDED 103 MOTION FILED] MOTION for SUMMARY JUDGMENT by Karyn Gil, Thomas Jacob Hass, Patrick Johnson, Jon Jumper, Dianne Knox, William L. Blaylock, Robert A. Conover, Edward L. Dobrowolski, Jr. Motion Hearing set for 8/13/2007 at 09:00 AM in Courtroom 3 (MCE) before Judge Morrison C. England Jr.. (Young, W.) Modified on 7/18/2007 (Marciel, M). (Entered: 07/13/2007)

July 13, 2007

July 13, 2007

PACER
99

MEMORANDUM of Points and Authorities in SUPPORT of 98 MOTION for SUMMARY JUDGMENT. (Young, W.) Modified on 7/16/2007 (Marciel, M). (Entered: 07/13/2007)

July 13, 2007

July 13, 2007

PACER
100

STATEMENT of Undisputed Material Facts in support of 98 Motion for Summary Judgment by plaintiffs Karyn Gil, Thomas Jacob Hass, Patrick Johnson, Jon Jumper, Dianne Knox, William L. Blaylock, Robert A. Conover, Edward L. Dobrowolski, Jr.. (Young, W.) Modified on 7/16/2007 (Marciel, M). (Entered: 07/13/2007)

July 13, 2007

July 13, 2007

PACER

Case Details

State / Territory: California

Case Type(s):

Equal Employment

Special Collection(s):

Private Employment Class Actions

Multi-LexSum (in sample)

Key Dates

Filing Date: Nov. 1, 2005

Closing Date: 2014

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Employees who pay compulsory fees to the CSEA and other unions, who are not members and who have, at one time or another, specifically objected to the use of their agency fees for politics or other non-bargaining activities.

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

California State Employees Association, Local 1000, Service Employees International Union, AFL-CIO-CLC, Union

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Freedom of speech/association

Equal Protection

Available Documents:

Trial Court Docket

Complaint (any)

Monetary Relief

Injunctive (or Injunctive-like) Relief

Non-settlement Outcome

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Preliminary injunction / Temp. restraining order

Damages

Source of Relief:

Litigation

Amount Defendant Pays: 1,216,588.93

Content of Injunction:

Preliminary relief granted

Post/Distribute Notice of Rights / EE Law

Implement complaint/dispute resolution process

Issues

General:

Records Disclosure