NEW ORLEANS (LN) — A federal judge on April 8, 2026 denied class certification to ten Filipino workers suing Grand Isle Shipyard LLC and its parent company GIS LLC under the Trafficking Victims Protection Act and Fair Housing Act, finding that individualized evidence about each worker’s experience would overwhelm any common questions in both the forced-labor and housing-discrimination claims.
The ruling in the Eastern District of Louisiana ends a certification fight that began with a January 2025 motion, survived an oral argument in June 2025, and required the plaintiffs to submit a proposed class damages model and trial plan before U.S. District Judge Carl J. Barbier denied the bid.
The named plaintiffs seek to represent two classes of Filipino B-1 visa holders who worked for GIS over several years. The TVPA class would span from June 28, 2012, and the FHA class from June 28, 2020.
At the heart of both claims is the allegation that GIS maintained an implicit but enforced policy preventing Filipino employees from leaving the company’s Galliano bunkhouse without permission while allowing non-Filipino workers to come and go freely. The plaintiffs also alleged discriminatory treatment during Hurricane Ida and COVID-19 quarantines on vessels.
The court began its analysis with Rule 23(b)(3)‘s predominance requirement, which tests whether proposed classes are sufficiently cohesive to warrant adjudication by representation.
On the TVPA forced-labor claim, Judge Barbier adopted the reasoning from David v. Signal Int’l, LLC, a 2012 decision from this district, over a contrary approach from the Central District of California in Nunag-Tanedo. The Signal court held that the TVPA’s forced-labor provision requires looking to the specific victim involved, including that person’s vulnerabilities and subjective response to the defendant’s conduct.
The court found that approach persuasive and necessary here. The plaintiffs argued that GIS’s alleged policy was so restrictive it rendered their work involuntary, but the court disagreed. None of the named plaintiffs testified they could not leave the bunkhouse building, and several described walking or jogging around the property for exercise. The plaintiffs could also leave for scheduled Walmart trips two to three times per week and occasional trips to Houma, Louisiana. The court noted that the named plaintiffs were able to leave the bunkhouse, get into a vehicle, and drive to Florida before this suit began.
GIS paid the plaintiffs both while working offshore and during on-call time at the bunkhouse. The plaintiffs voluntarily renewed their employment contracts multiple times, and GIS paid airfare back to the Philippines of each term regardless of whether an employee completed the full contract.
The court noted that, as in Signal, this case involves paid workers who in fact could leave their jobs at any time.
The court also pointed to twenty-five signed declarations from putative class members submitted stating they could leave the bunkhouse of their own free will. The plaintiffs’ evidence, by contrast, relied on conflicting deposition testimony revealing individual experiences unique to each plaintiff.
The court found that resolving whether GIS coerced any particular worker would require looking to the details surrounding each alleged threat, determining whether it occurred, and assessing whether it was sufficient to compel that specific employee to continue working. Because individual issues of coercion and consent predominate, the court denied certification of the forced-labor claims.
The trafficking claims under 18 U.S.C. § 1590 and the conspiracy provision at 18 U.S.C. § 1594(b) are premised on the forced-labor claims. The court found they cannot be tried on a classwide basis for the same reason.
On the FHA claims, the court reached the same conclusion. The plaintiffs’ theory rests on whether GIS had a classwide policy of treating Filipino workers differently in housing, but the evidence of that policy comes from conflicting anecdotal accounts unique to each plaintiff. The plaintiffs pointed to no formal GIS policy treating Filipino employees differently, and the court found no case certifying FHA claims of this nature.
The court denied the motion in full.