Justia California Supreme Court Opinion Summaries

This case involves a wage dispute between an employee and his employer. The employee, George Huerta, filed a class action against his employer, CSI Electrical Contractors, seeking payment for unpaid hours worked. The case revolved around the interpretation of the Industrial Welfare Commission's Wage Order No. 16 and the term "hours worked."The Supreme Court of California was asked by the United States Court of Appeals for the Ninth Circuit to answer three questions related to Wage Order No. 16. The first question was whether time spent waiting to exit a security gate on the employer's premises was compensable as "hours worked". The court concluded that it was, as the employer's mandated exit procedure, including vehicle inspection, signified a level of control over the employee.The second question was whether time spent driving between the security gate and employee parking lots while subject to employer-imposed rules was compensable. The court held that it could be compensable as "employer-mandated travel" if the security gate was the first location where the employee's presence was required for an employment-related reason other than accessing the worksite. However, this travel time was not considered "hours worked" as the employer's rules did not imply a requisite level of control.Lastly, the court was asked whether time spent on the employer's premises during an unpaid meal period, when workers were prohibited from leaving but not required to engage in employer-mandated activities, was compensable as "hours worked". The court held that it was, as the employer's prohibition on leaving the premises prevented the employee from engaging in personal activities. The employee could bring an action to enforce the wage order and recover unpaid wages for that time. View "Huerta v. CSI Electrical Contractors" on Justia Law

In the Supreme Court of California, the case revolved around the question of whether trial courts have the inherent authority to dismiss a claim under the Labor Code Private Attorneys General Act of 2004 (PAGA) on the grounds of manageability. PAGA permits aggrieved employees to act as private attorneys general to recover civil penalties on behalf of the state for Labor Code violations. In this case, defendant Royalty Carpet Mills, Inc. (Royalty) argued that trial courts should have the power to dismiss PAGA claims if they are deemed unmanageable.The Supreme Court of California held that trial courts do not have the inherent authority to dismiss PAGA claims on manageability grounds. The court emphasized that trial courts do not generally possess a broad inherent authority to dismiss claims, nor is it appropriate for them to dismiss PAGA claims by using class action manageability requirements. The court also affirmed the judgment of the Court of Appeal, which had reached the same conclusion.The court also discussed the facts of the case. Jorge Luis Estrada and Paulina Medina, former employees of Royalty, brought a PAGA claim against the company for alleged violations of Labor Code provisions requiring the provision of meal periods. The trial court certified a class action suit and later decertified it, dismissing the PAGA claim on manageability grounds. The Court of Appeal reversed this decision, which led to Royalty's appeal to the Supreme Court.The Supreme Court stated that while trial courts may use various tools to efficiently manage PAGA claims, striking such claims due to manageability concerns is not among these tools. It also noted that while trial courts and the Labor and Workforce Development Agency (LWDA) share discretion in assessing a civil penalty, the trial court's discretion does not extend to determining which cases can be investigated and enforced, a power reserved for the LWDA.The Supreme Court further rejected the argument that the retrial of the plaintiffs' representative PAGA claim would violate Royalty's right to due process. It stated that while defendants have a due process right to present an affirmative defense, this does not include the right to present the testimony of an unlimited number of individual employees. It also concluded that trial courts lack inherent authority to dismiss a PAGA claim on manageability grounds to protect a defendant's due process rights. However, the court left open the possibility that a defendant could show that a trial court's use of case management techniques so abridged the defendant's right to present a defense that its right to due process was violated.The Supreme Court affirmed the judgment of the Court of Appeal, and remanded the case for further proceedings consistent with its opinion. View "Estrada v. Royalty Carpet Mills, Inc." on Justia Law

The Supreme Court held that an employer's business entity agents can be held directly liable under the California Fair Employment and Housing Act (FEHA), Cal. Gov. Code 12900 et seq., for employment discrimination in appropriate circumstances when the business entity agent has at least five employees and carries out activities regulated by FEHA on behalf of an employer.Plaintiffs, on behalf of themselves and an alleged class, brought this action alleging claims under the FEHA, the Unruh Civil Rights Act, unfair competition law, and the common law right of privacy. Plaintiffs named as a defendant U.S. Healthworks Medical Group (USHW), who was acting as an agent of Plaintiffs' prospective employers. The district court dismissed all claims, concluding, as relevant to this appeal, that the FEHA does not impose liability on the agents of a plaintiff's employer. The federal district court of appeals certified a question of law to the Supreme Court, which answered that FEHA permits a business entity acting as an agent of an employer to be held directly liable as an employer for employment discrimination, in violation of FEHA, when the business entity has at least five employees and carries out FEHA-regulated activities on behalf of an employer. View "Raines v. U.S. Healthworks Medical Group" on Justia Law

The Supreme Court held that an aggrieved employee who has been compelled to arbitrate claims under the Private Attorneys General Act of 2004 (PAGA), Cal. Lab. Code 2698 et seq., that are "premised on Labor Code violations actually sustained by" Plaintiff maintains statutory standing to pursue PAGA claims arising out of events involving other employees in court.The Supreme Court reversed the judgment of the court of appeals holding that the trial court properly found, among other things, that PAGA claims are not subject to arbitration, holding (1) to have PAGA standing, a plaintiff must be an "aggrieved employee" - i.e., one who was employed by the alleged violator and against whom one or more of the alleged violations was committed; and (2) when a plaintiff brings a PAGA action composed of both individual and non-individual claims, "an order compelling arbitration of the individual claims does not strip the plaintiff of standing to proceed as an aggrieved employee to litigate claims on behalf of other employees under PAGA." View "Adolph v. Uber Technologies, Inc." on Justia Law

The Supreme Court held that the exclusivity provisions of the California Workers' Compensation Act (WCA), Cal. Lab. Code 3200 et seq., do not bar an employee's spouse's negligence claim against the employer when the spouse is injured by transmission of the COVID-19 virus but that an employer does not owe a duty of care under California law to prevent the spread of COVID-19 to employees' household members.The Supreme Court answered two questions of California law certified from the United States Court of Appeals for the Ninth Circuit regarding the scope of an employer's liability when an employee's spouse is injured by transmission of the COVID-19 virus as follows: (1) the exclusivity provisions of the WCA do not bar a non-employee's recovery for injuries that are not legally dependent upon an injury suffered by the employee; and (2) employers do not owe a tort-based duty to non-employees to prevent the spread of COVID-19. View "Kuciemba v. Victory Woodworks, Inc." on Justia Law

The Supreme Court held that a report of unlawful activities made to an employer or agency that already knew about the violation is a protected "disclosure" within the meaning of Cal. Labor Code 1102.5(b).Employer fired Employee after Employee complained about unpaid wages she was owed, threatened to report her to immigration authorities, and told her never to return to the establishment. The Labor Commissioner sued Employer for violations of section 1102.5, but the trial court ruled against Labor Commissioner on the claim because Employee reported her complaints to Employer rather than a government agency. The court of appeal affirmed. The Supreme Court reversed, holding that Employee made a disclosure protected by section 1102.5(b). View "People ex rel. Garcia-Brower v. Kolla's, Inc." on Justia Law

The Supreme Court affirmed the judgment of the court of appeal affirming the judgment of the trial court against a hospital based on violations of the Labor Code and the Unfair Competition Law, holding that the lower court correctly found that claim preclusion did not bar this suit.A nurse sued the staffing agency that arranged for her to work at at a hospital based on violations of the Labor Code and the Unfair Competition Law. The parties settled. Thereafter, the nurse sued the hospital based on the same alleged violations. The hospital argued that the first judgment precluded the nurse from bringing the second suit. The trial court concluded that the hospital was not in privity with the staffing agency for claim preclusion purposes. The Supreme Court affirmed, holding that the hospital was not entitled to benefit from claim preclusion. View "Grande v. Eisenhower Medical Center" on Justia Law

The Supreme Court held that the additional hour of pay an employer must pay an employee if the employer unlawfully makes the employee work during all or part of a meal or rest period constitutes "wages" that must be reported on statutorily-required wage statements during employment and paid within statutory deadlines when an employee leaves the job.Plaintiff, who was suspended from his job as a guard after leaving his post to take a meal break. Plaintiff filed a putative class action on behalf of employees of Defendant seeking an additional hour of pay, so-called "premium pay," for each day on which Defendant failed to provide employees a legally-compliant meal break. The trial court determined that Defendant had violated the meal break laws for a certain period and that a failure to pay meal break premiums could support claims under the wage statement and timely payment statutes. The court of appeal reversed in part. The Supreme Court remanded the case, holding (1) the court of appeal erred in concluding that extra pay for missed breaks does not constitute "wages" to be reported on wage statements during employment; and (2) the seven percent default rate of prejudgment interest set by the state Constitution applies to amounts due for failure to provide meal and rest breaks. View "Naranjo v. Spectrum Security Services, Inc." on Justia Law

The Supreme Court held that Cal. Labor Code 1102.6 governs whistleblower retaliation claims brought pursuant to Cal. Labor Code 1102.5.Since 2003, section 1102.6 has prescribed a framework for presenting and evaluating retaliation claims brought under section 1102.5. Since 2003, some courts continued to apply the burden-shifting framework borrowed from the decision in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973). The trial court granted summary judgment for Defendant on Plaintiff's whistleblower retaliation claim in this case, concluding that Plaintiff could not satisfy the third step of the McDonnell Douglas test. The Ninth Circuit Court of Appeal certified a question regarding the correct standard to the Supreme Court. The Supreme Court answered that section 1102.6 provides the governing framework for the presentation and evaluation of whistleblower retaliation claims brought under section 1102.5. View "Lawson v. PPG Architectural Finishes, Inc." on Justia Law

In this case involving the In-Home Supportive Services (IHSS) program the Supreme Court affirmed the judgment of the court of appeal concluding that sections 631 and 683 of the Unemployment Insurance Code exclude from coverage a provider who is the recipient's minor child, parent, or spouse under the state's unemployment insurance program, holding that the court of appeal did not err.The IHSS program authorized certain Californias, who were disabled or elderly, to receive in-home services from third parties or family members paid for with public funds. Under one program option, service recipients hire their own providers and the providers are paid either by a public entity or by the recipients with funds they have received from a public entity. At issue was whether such a provider qualified for unemployment benefits. The Supreme Court answered the question in the negative, holding that provider who is the recipient's minor child, parent, or spouse is not covered by the state's unemployment insurance program. View "Skidgel v. California Unemployment Insurance Appeals Board" on Justia Law