Adam Martinez worked as an emergency medical technician (EMT) for Sierra Lifestar, Inc. — an ambulance company serving Tulare County — for roughly ten months, from September 2019 to July 2020. During that tenure he received a single bonus: a $109.47 “EMS Bonus” paid in May 2020 in recognition of National Emergency Medical Services Week, netting him $100 after withholdings. Lifestar paid that bonus to all of its employees that week.

Martinez filed a class action in July 2023 on behalf of himself and approximately 135 current and former Lifestar employees. His theory was straightforward: California law requires that nondiscretionary bonuses be folded into an employee’s “regular rate of pay” when calculating overtime, double time, and meal and rest period premium pay. (Lab. Code, §§ 510, 226.7.) Lifestar, he alleged, paid ten categories of bonuses — including EMS Bonuses, Sign-On Bonuses, Paramedic Bonuses, Preceptor Bonuses, and others — but systematically excluded every one of them when computing those elevated rates, causing class-wide underpayment. An expert who reviewed Lifestar’s payroll data estimated the potential overtime and double-time shortfall at roughly $462,000, with an additional $32,000 in unpaid meal premiums.

In March 2025, the trial court denied Martinez’s motion for class certification on a single ground: Martinez had failed to show his claim was typical of the proposed class. The court reasoned that Lifestar paid ten different types of bonuses, each with its own criteria, and that various exclusions listed in the Division of Labor Standards Enforcement (DLSE) Policies and Interpretations Manual could apply differently to each bonus type. Specifically, the court found a “significant possibility” that Martinez faced defenses unique to him — namely, that his EMS Bonus was either a gift or a purely discretionary payment — which could distract from the broader class litigation and swamp the common issues. The court declined to reach the separate question of whether common questions of law or fact actually predominated across the ten bonus categories.

The Fifth District Court of Appeal reversed the denial of class certification in the published case of Martinez v. Sierra Lifestar, Inc. Case No. F089576 (April 2026) and remanded for further proceedings. The court did not direct the trial court to certify the class outright, instead acknowledging that several certification criteria beyond typicality had never been addressed below and warranted fresh consideration on remand. The appellate panel noted that the trial court retains discretion on remand to consider whether to narrow the proposed class or to create subclasses organized around particular bonus types.

The court’s analysis turned on a single legal error: the trial court misunderstood what “unique” means in the class-action typicality context.

Typicality is not a demanding standard. Citing Seastrom v. Neways, Inc. (2007) 149 Cal.App.4th 1496, 1502, the court restated the familiar three-part test: typicality is satisfied when (1) other members suffered the same or similar injury, (2) the action rests on conduct not unique to the named plaintiff, and (3) other class members were harmed by the same course of conduct. Quoting Mullen v. Treasure Chest Casino, LLC (5th Cir. 1999) 186 F.3d 620, 625, the panel emphasized that federal courts consistently describe typicality as “not demanding,” and that California has never required a class representative to have interests identical to those of every class member. Classen v. Weller (1983) 145 Cal.App.3d 27, 46.

The “unique defense” doctrine was misapplied. A proposed representative’s claim may fail typicality if it is subject to a defense peculiar to that plaintiff alone — one that would distract from the claims of the rest of the class. CE Design Ltd. v. King Architectural Metals, Inc. (7th Cir. 2011) 637 F.3d 721, 726. But where a defense applies broadly across the class, it cannot defeat typicality for the representative. Here, Lifestar’s argument — that EMS Bonuses paid during National Emergency Medical Services Week were gift-like or discretionary — applied with equal force to all 51 other employees who received the same EMS Bonus under the same circumstances. Lifestar’s own vice-president testified that no bonuses of any kind were ever included in overtime calculations. The defense was class-wide, not individual.

The evidence compelled the opposite conclusion. Even construing the trial court’s ruling as a factual finding, the appellate court held it was unsupported by substantial evidence. Payroll data, pay stubs, and the analyses of both parties’ own witnesses uniformly showed that Martinez’s situation mirrored that of his fellow EMS Bonus recipients. There was nothing about his claim that set it apart from theirs. Under Brinker Restaurant Corp. v. Superior Court (2012) 53 Cal.4th 1004, 1022, a certification ruling based on erroneous legal assumptions cannot stand, and under Ayala v. Antelope Valley Newspapers, Inc. (2014) 59 Cal.4th 522, 530, reversal is required whenever the stated reasons for a ruling are legally infirm — even if other reasons might theoretically have supported the same outcome.

Trial Court Denial of Workers’ Class Action Certification Reversed