Unreported / Non-Citable
Background
Richard Anthony Ybarra sued Hyatt Corporation in a putative wage and hour class action that was removed to the Northern District of California on May 12, 2025. On August 26, 2025, the then-assigned judge set a September 26, 2025 deadline to add parties and amend pleadings. Although the case was later reassigned, the reassignment order expressly stated that briefing schedules and other deadlines, including those for amending pleadings, remained unchanged, so the September 26, 2025 deadline stayed in force. Almost eleven months after that deadline passed, on August 21, 2026, Ybarra filed a motion seeking leave to file an amended complaint.
Ybarra proposed four changes: adding Allison Castro as a named plaintiff, adding a claim for inaccurate and incomplete wage statements under Labor Code Section 226(a), adding a cause of action for penalties under the Private Attorneys General Act, and adding allegations about off-the-clock bag checks and COVID-19 screenings. Hyatt did not oppose adding Castro as a named plaintiff or adding Castro's timely wage statement and PAGA claims, but it contested the remaining amendments.
The Court’s Holding
Judge Rita F. Lin granted the motion in part and denied it in part. Because Hyatt did not oppose adding Castro as a named plaintiff or adding Castro's timely wage statement and PAGA claims, the court granted leave as to those proposed amendments. For the remaining amendments, the court held that because Ybarra sought to amend long after the court-set deadline, he had to show good cause under Federal Rule of Civil Procedure 16, which primarily considers the diligence of the party seeking the amendment. The court found Ybarra had not shown the requisite diligence, so the motion was otherwise denied.
The court rejected Ybarra's own Section 226 claim because he did not claim diligence and offered no explanation for waiting despite having long had access to the allegedly inaccurate wage statements. It also found that Castro's Section 226 claim could not relate back to the original filing date because it required additional factual allegations and separate wage-statement evidence. Similarly, Castro's PAGA claim could not relate back because PAGA notice is a condition precedent to filing suit, and no notice had been given before Ybarra filed his initial complaint; the amendment was therefore limited to the time periods justified by Castro's own administrative exhaustion. Finally, the court found no good cause for the bag-check and COVID-screening allegations because Ybarra waited over four months after Castro's April 8, 2026 LWDA letter to seek amendment, and Castro's claims on those issues would be futile because the alleged conduct occurred from approximately March 2020 to 2022 and was time-barred under California's three-year statute of limitations. The order directs Ybarra to file any compliant amended complaint by November 6, 2026, with Hyatt's response due November 20, 2026.
Key Takeaways
- Parties seeking to amend pleadings after a court-set deadline must demonstrate good cause under Rule 16, which primarily considers the diligence of the party seeking the amendment; if the party was not diligent, the inquiry ends.
- Late amendments to assert new theories are not reviewed favorably when the facts and the theory have been known to the party since the inception of the cause of action.
- An amendment will not relate back to the original filing date when the amended complaint must include additional facts and evidence to support the new claim.
- PAGA notice is a condition precedent to filing suit, so a later amendment cannot retroactively bestow administrative compliance that did not exist when the plaintiff filed the initial complaint.
- Claims arising from conduct occurring approximately from March 2020 to 2022 are time-barred under California's three-year statute of limitations for wage and hour causes of action if suit is filed in 2026 without a basis for tolling.
Why It Matters
This order reinforces the importance of diligence in seeking leave to amend pleadings after a scheduling deadline has passed, and it confirms that a reassignment does not revive an expired amendment deadline when the reassignment order preserves existing schedules. The court granted the unopposed amendments—adding Castro as a named plaintiff and her timely wage-statement and PAGA claims—based on Hyatt's non-opposition, while applying the Rule 16 good-cause and diligence analysis only to the remaining contested amendments, which it denied, and it cabined the permitted claims to the periods justified by Castro's own administrative exhaustion and the applicable limitations periods.
The decision also clarifies the limits of relation-back doctrine in wage and hour litigation: new claims do not relate back when they require additional factual allegations or separate evidence, and statutory prerequisites like PAGA exhaustion cannot be satisfied retroactively. The ruling allows the case to proceed with an additional named plaintiff and certain timely claims while protecting defendants from stale, time-barred allegations.