Justia California Supreme Court Opinion Summaries

A charter city entered into certain contracts for the construction of public buildings. A federation of labor unions then petitioned the superior court for a peremptory writ of mandate, asserting that the city must comply with California's prevailing wage law notwithstanding local ordinances stating otherwise. The prevailing wage law requires that certain minimum wage levels be paid to contract workers constructing public works. At issue on appeal was whether, under the state constitution, the subject matter of the state's prevailing wage law was a "statewide concern" over which the state has primary legislative authority, or whether the matter was a municipal affair and therefore governed by the charter city's local ordinances. The Supreme Court affirmed the court of appeal, which in turn affirmed the trial court's judgment denying the union's petition for a writ of mandate, holding that there was no statewide concern at issue in this case, and therefore, the state's prevailing wage law did not apply to the charter city. View "State Bldg. & Constr. Trades Council v. City of Vista" on Justia Law

After a school district (District) approved the conversion of an existing public school into a charter school, a union (UTLA) claimed that the District failed to comply with collective bargaining agreement provisions (CBPs) concerning charter school conversion. UTLA petitioned to compel arbitration pursuant to the collective bargaining agreement. The trial court denied the petition, finding that the collective bargaining provisions (CBPs) regulating charter school conversion were unlawful because they conflicted with the Education Code, and therefore, arbitration of those unlawful provisions should not be compelled. The court of appeals reversed, holding that the court's function in adjudicating a petition to compel arbitration was limited to determining whether there was a valid arbitration agreement that had not been waived. The Supreme Court reversed, holding (1) a court faced with a petition to compel arbitration to enforce CBPs between a union and a school district should deny the petition if the CBPs at issue directly conflict with provisions of the Education Code; and (2) because UTLA had not identified with sufficient specificity which CBPs the District allegedly violated, the case was remanded for identification of those specific provisions and to address whether the provisions conflicted with the Education Code. View "United Teachers of L.A. v. L.A. Unified Sch. Dist." on Justia Law

Plaintiffs sued IFP and multiple DOE defendants for violating various labor laws as well as the unfair competition law (UCL)(Bus. & Prof. Code, 17200 et seq.). The amended complaint stated seven claims, the sixth of which alleged the failure to provide rest breaks as required by Labor Code 226.7. Plaintiffs ultimately dismissed this claim with prejudice after settling with the DOE defendants. IFP subsequently moved for attorney's fees under Labor Code 218.5. The trial court awarded fees and the Court of Appeal affirmed. The court concluded, in light of the relevant statutory language and legislative history, that neither Labor Code 1194 nor 218.5 authorized an award of attorney's fees to a party that prevailed on a section 226.7 claim. Accordingly, the court reversed on this claim and affirmed the judgment on plaintiffs' other claims. View "Kirby, et al. v. Imoos Fire etc." on Justia Law

The Enterprise Zone Act, Gov. Code, 7070 et seq., was enacted "to stimulate business and industrial growth" in "areas within the state that are economically depressed due to a lack of a private sector." Among the incentives available to businesses that operated within an enterprise zone was a hiring tax credit in the amount of a percentage of the wages paid to a "qualified employee." Rev. & Tax. Code, 23622.7, subd. (a). The Franchise Tax Board conducted an audit and refused to accept some of the certifications that Dicon claimed for a hiring tax credit. The Board found that the documents Dicon produced to establish that workers were "qualified employees" were insufficient and denied the requested tax credit in part. The court reversed the appellate court's holding that a certification issued by a governmental agency for purposes of the hiring tax credit under section 23622.7 constituted "prima facie proof a worker is a 'qualified employee,'" which shifted to the Board the "burden of demonstrating an employee is not a qualified worker for which no voucher should have issued." In all other respects, the Board did not challenge the appellate court's judgment and the judgment was affirmed. View "Dicon Fiberoptics v. Franchise Tax Bd." on Justia Law

This case stemmed from the DLSE's investigation into whether Brinker was complying with its obligations to provide rest and meal breaks to its employees, maintain proper records, and pay premium wages in the event required breaks were not provided. The court considered on appeal issues of significance to class actions generally and to meal and rest break class actions in particular. The court concluded that the trial courts were not obligated as a matter of law to resolve threshold disputes over the elements of a plaintiff's claims, unless a particular determination was necessarily dispositive of the certification question. Because the parties have so requested, however, the court nevertheless addressed several threshold disputes. In regards to the nature of an employer's duty to provide meal periods, the court concluded that an employer's obligation was to relieve its employee of all duty, with the employee thereafter at liberty to use the meal period for whatever purpose he or she desired, but the employer need not ensure that no work was done. Further, in light of the substantial evidence submitted by plaintiffs of defendants' uniform policy, the court concluded that the trial court properly certified a rest break subclass. On the question of meal break subclass certification, the court remanded to the trial court for reconsideration. With respect to the third contested subclass, covering allegations that employees were required to work "off-the-clock," no evidence of common policies or means of proof was supplied, and the trial court therefore erred in certifying a subclass. View "Brinker Restaurant Corp. v. Super. Ct. of San Diego Cty" on Justia Law

Plaintiffs, claims adjusters employed by defendants, filed four class action lawsuits alleging defendants erroneously classified them as exempt "administrative" employees, seeking damages based on unpaid overtime work. At issue was whether plaintiffs were exempt employees, not entitled to overtime compensaution under the Labor Code and regulations of the California Industrial Welfare Commission (IWC). The court held that the Court of Appeal misapplied the substantive law when its analysis focused on Wage Order 4. The court held that, in resolving whether work qualified as administrative, courts must consider the particular facts before them and apply the language of the statutes and wage orders at issue. Only if those sources failed to provide adequate guidance, was it appropriate to reach out to other sources. Accordingly, the court reversed and remanded. View "Harris v. Super. Ct." on Justia Law

This case stemmed from a lawsuit filed in 2007 by the Retired Employees Association of Orange County, Inc. against the County of Orange contesting the validity of certain changes the county had made to health benefits for retired employees. At the request of the Ninth Circuit, the court addressed the following question: "Whether, as a matter of California law, a California county and its employees can form an implied contract that confers vested rights to health benefits on retired county employees." In response, the court concluded that, under California law, a vested right to health benefits for retired county employees could be implied under certain circumstances from a county ordinance or resolution. Whether those circumstances existed in this case was beyond the scope of the question posed to the court by the Ninth Circuit. View "Retired Employees Assoc. v. Co. of Orange" on Justia Law

This case stemmed from injuries Anthony Verdon Lujan sustained when his arm got caught on a luggage conveyor when he was inspecting the conveyor as an employee of Lloyd W. Aubry Co. (Aubrey), an independent contractor hired by US Airways to maintain and repair the conveyor. Aubry's workers' compensation insurer paid Verdon benefits based on the injury and subsequently sued US Airways seeking what it paid in benefits. Verdon intervened as plaintiff in the action, alleging causes of action for negligence and premises liability. At issue was whether the Privette v. Superior Court rule applied when the party that hired the contractor (the hirer) failed to comply with workplace requirements concerning the precise subject matter of the contract and the injury was alleged to have occurred as a consequence of that failure. The court held that the Privette rule did apply in that circumstance. The court concluded that, by hiring an independent contractor, the hirer implicitly delegated to the contractor any tort law duty it owed to the contractor's employees to ensure the safety of the specific workplace that was the subject of the contract. That implicit delegation included any tort law duty the hirer owed to the contractor's employees to comply with applicable statutory or regulatory safety requirements. Accordingly, plaintiffs here could not recover in tort from US Airways on a theory that Verdon's workplace injury resulted from defendant's breach of what plaintiffs described as a nondelegable duty under California Occupational Safety and Health Act of 1973 (OSHA), Cal. Code Regs., tit. 8, sections 3999, 4002, regulations to provide safety guards on the conveyor. Therefore, the court erred in reversing the trial court's grant of summary judgment for defendant. View "Seabright Ins. v. US Airways" on Justia Law

In this case, the court construed Labor Code section 4659(c), which provided for the annual indexing of two categories of workers' compensation benefits, total permanent disability and life pension payments, to yearly increases in the state's average weekly wage (SAWW), so that lifetime disability payments made to the most seriously injured workers would keep pace with inflation. The indexing procedure was sometimes referred to as an "escalator," or one providing for "cost of living adjustments" (COLA's). At issue was whether the operative language of section 4659(c) required the annual COLA's for total permanent disability and life pension payments to be calculated (1) prospectively from the January 1 following the year in which the worker became "entitled to receive a life pension or total disability indemnity," (when the payments actually commenced); (2) retroactively to January 1 following the year in which the worker sustained the industrial injury; or (3) retroactively to January 2004, in every case involving a qualifying industrial injury, regardless of the date of injury or the date the first benefit payment became due. Applying fundamental rules of statutory construction, the court held that the Legislature intended that COLA's be calculated and applied prospectively commencing on the January 1 following the date on which the injured worker first became entitled to receive, and actually began receiving, such benefits payments, i.e., the permanent and stationary date in the case of total permanent disability benefits, and the date on which partial permanent disability benefits became exhausted in the case of life pension payments. View "Baker v. Workers' Comp. App. Bd." on Justia Law

Plaintiff filed a complaint against the City seeking to enjoin enforcement of the Grocery Worker Retention Ordinance, L.A. Ord. No. 177, 231, adding ch. XVIII, 181.00 et seq. to L.A. Mun. Code. The ordinance vested current grocery store employees with certain individual rights during a 90-day transition period. At issue was whether the worker retention ordinance was preempted as intruding upon either matters of health and safety already regulated by the state or matters of employee organization and collective bargaining fully occupied by federal law. The court held that the challenged ordinance was fully consistent with both the state and federal equal protection clauses and reversed the court of appeal's judgment. View "California Grocers Assoc. v. City of Los Angeles" on Justia Law