The Massachusetts Supreme Judicial Court (SJC) recently discussed class certification in state court wage and hour cases in Gammella v. P.F. Chang’s China Bistro.1 The SJC held that the same civil procedure rules applicable to other class actions also apply to wage claims. It also found that uncertainty in the exact number of persons who might have a valid claim is not a reason for denying class action treatment. The SJC further held that making an offer of judgment to a class action plaintiff that includes all potential relief she might recover does not extinguish that person’s claims.
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