Justia California Supreme Court Opinion Summaries

At issue in this case was California wage order requirements that an employer provide suitable seating for employees under certain circumstances. In two related federal appeals, the Ninth Circuit certified three questions to the Supreme Court regarding wage orders stating that “[a]ll working employees shall be provided with suitable seats when the nature of the work reasonably permits the use of seats.” The Court answered the questions as follows: (1) the “nature of the work” refers to an employee’s tasks performed at a given location for which a right to a suitable seat is claimed, and if the tasks being performed at a given location reasonably permit sitting and provision of a seat would not interfere with the employee’s tasks that require standing, a seat is called for; (2) whether the nature of the work “reasonably permits” sitting is a question to be determined objectively based on the totality of the circumstances; and (3) if an employer argues that there is no suitable seat available, the burden is on the employer to show that compliance is infeasible. View "Kilby v. CVS Pharmacy, Inc." on Justia Law

As a condition of her employment with Defendants, Plaintiff signed an agreement to resolve any employment-related disputes through arbitration. After Plaintiff resigned, she filed a complaint against Defendants, alleging that she suffered harassment, discrimination, and retaliation during the course of her employment. Defendants filed a motion to compel arbitration. Plaintiff opposed the motion, asserting that it was unconscionable. The trial court agreed with Plaintiff and denied the motion to compel arbitration. The court of appeal reversed. The primary issue before the Supreme Court was whether the arbitration agreement was unconscionable because of a clause in the agreement providing that, in the event a claim proceeds to arbitration, the parties are authorized to seek preliminary injunctive relief in the superior court. The Supreme Court affirmed, holding that the arbitration agreement was not unconscionable because the clause did no more that restate existing law. View "Baltazar v. Forever 21, Inc." on Justia Law

As a condition of her employment with Defendants, Plaintiff signed an agreement to resolve any employment-related disputes through arbitration. After Plaintiff resigned, she filed a complaint against Defendants, alleging that she suffered harassment, discrimination, and retaliation during the course of her employment. Defendants filed a motion to compel arbitration. Plaintiff opposed the motion, asserting that it was unconscionable. The trial court agreed with Plaintiff and denied the motion to compel arbitration. The court of appeal reversed. The primary issue before the Supreme Court was whether the arbitration agreement was unconscionable because of a clause in the agreement providing that, in the event a claim proceeds to arbitration, the parties are authorized to seek preliminary injunctive relief in the superior court. The Supreme Court affirmed, holding that the arbitration agreement was not unconscionable because the clause did no more that restate existing law. View "Baltazar v. Forever 21, Inc." on Justia Law

At issue in this case was whether Cal. Labor Code 4458.2, which provides workers’ compensation benefits to certain peace officers injured in the line of duty, applies to both volunteer peace officers and to regularly sworn, salaried officers. While employed as a police officer by the City of Marysville, John Larkin sustained injuries in the course of duty. A workers’ compensation judge determined that Larkin was entitled to workers’ compensation benefits but not to the maximum indemnity levels available under section 4458.2 because section 4458.2 did not apply to regularly sworn, salaried officers like Larkin. The Workers’ Compensation Appeals Board denied Larkin’s petition for reconsideration. The Court of Appeal affirmed. The Supreme Court affirmed, holding that a review of the legislative history governing the relevant statutory provisions of section 4458.2 leads to the conclusion that the statute does not extend maximum disability indemnity levels to regularly sworn, salaried peace officers. View "Larkin v. Workers’ Comp. Appeals Bd." on Justia Law

The supervisor of Plaintiff, a firefighter, maintained a “daily log” regarding the employees he supervised. The daily log consisted of notes that memorialized the supervisor’s thoughts and observations of employees, which he used as a memory aid in preparing performance plans and reviews. Plaintiff and the Orange County Professional Firefighters Association filed suit seeking to require Defendants to comply with Cal. Gov't Code 3255 before including adverse comments in Plaintiff’s personnel files. Specifically at issue was whether section 3255, which gives a firefighter the right to review and respond to any negative comment entered into his or her personnel file “or any other file used for any personnel purposes by his or her employer,” gave Plaintiff the right to review and respond to negative comments in the supervisor’s daily log. The Court of Appeal concluded that section 3255 required that Plaintiff be given an opportunity to respond to the negative comments in the log before they were made known to the employer. The Supreme Court reversed, holding that because the log was not shared with or available to anyone other than the supervisor who wrote the log, it did not constitute a file “used for any personnel purposes by his or her employer,” and therefore, section 3255 did not apply. View "Poole v. Orange County Fire Auth." on Justia Law

In 2008, Brandon Clark fell ten feet while working as a carpenter for Employer. Clark’s workers’ compensation doctor prescribed various drugs to treat Clark’s injuries, and Clark’s personal doctor prescribed additional drugs. In 2009, Clark died from the “combined toxic effects of the four sedating drugs detected in his blood with associated early pneumonia.” Clark’s family sought workers’ compensation death benefits, arguing that the medications Clark was prescribed for his work-related injuries caused his death. The workers’ compensation judge awarded death benefits to the family. The Court of appeal reversed, concluding that there was insufficient evidence that the drugs Clark was prescribed for his work injuries contributed to his death. The Supreme Court reversed, holding (1) the Court of Appeal wrongly applied a higher proximate cause standard to this wrongful death case than the Legislature intended; and (2) substantial evidence supported the WCJ’s finding that two drugs, prescribed by the workers’ compensation doctor for Clark’s industrial injury, contributed to his death. View "South Coast Framing v. Workers’ Comp. Appeals Bd." on Justia Law

Plaintiff, a firefighter, sued Defendant, his employer, alleging disability discrimination in violation of the California Fair Employment and Housing Act (FEHA). The trial court granted summary judgment in favor of Defendant. Without making any finding that Plaintiff’s action was frivolous, unreasonable, or groundless, the trial court awarded Defendant its court costs. The court of appeal affirmed. The Supreme Court reversed, holding (1) Cal. Gov’t Code 12965(b) governs cost awards in FEHA actions, allowing trial courts discretion in awards of both attorney fees and costs to prevailing FEHA parties; and (2) the standard set forth in Christiansburg Garment Co. v. EEOC applies to discretionary awards of both attorney fees and costs to prevailing FEHA parties under section 12965(b), but a prevailing defendant should not be awarded fees or costs unless the plaintiff brought or continued litigating the action without an objective basis for believing it had potential merit. View "Williams v. Chino Valley Indep. Fire Dist." on Justia Law

Under the Freeway Service Patrol (FSP) Act, motorists receive emergency roadside assistance on California’s highways. The FSP program is administered by, among other agencies, the Department of the California Highway Patrol (CHP). Local agencies then contract with privately owned tow services, which provide trucks dedicated to the FSP program. One local agency contracted with California Coach Orange, Inc. for FSP tow services and also contracted with CHP for field supervision and program management. Joshua Guzman, a California Coach FSP tow truck driver, hit a car on an interstate highway, injuring Plaintiff. Plaintiff sued CHP, among other defendants, seeking recovery on the theory that CHP was Guzman’s “special employer.” The trial court denied CHP’s motion for summary judgment. The Court of Appeal reversed, ruling that CHP cannot be the special employer of an FSP tow truck driver as a matter of law. The Supreme Court reversed, holding (1) the Court of Appeal erred by ruling that FSP statutes categorically bar CHP from acting as a special employer; and (2) the language of the statutory scheme does not support a finding that CHP is the special employer of FSP tow truck drivers, but this conclusion does not eliminate the possibility that CHP might act as a special employer in particular circumstances. View "State ex rel. Dep’t of Cal. Highway Patrol v. Superior Court" on Justia Law

An Employee was terminated for engaging in outside employment in violation of company policy during his absence on approved medical leave. The Employee sued, arguing that the Employer violated his right to reinstatement under the Moore-Brown-Roberti Family Rights Act (CFRA) and the federal Family and Medical Leave Act. The trial court granted the Employer’s motion to compel arbitration. The arbitrator relied on the federal “honest belief” defense and rejected Plaintiff’s contentions. The Court of Appeals vacated the award in the Employer’s favor, concluding that the arbitrator violated Plaintiff’s right to reinstatement under the CFRA when he applied the honest belief defense to Plaintiff’s claim. The Supreme Court reversed, holding that, although the arbitrator may have committed error in adopting the honest belief defense, any error did not deprive the Employee of an unwaivable statutory right because the arbitrator relied on the substantial evidence that the Employee violated his Employer’s written policy prohibiting outside employment while he was on medical leave. View "Richey v. Autonation, Inc." on Justia Law

Security guards employed by CPS Security Solutions, Inc. filed two class action lawsuits - which were later consolidated - alleging that CPS’s on-call compensation policy violated minimum wage and overtime obligations imposed by the applicable Industrial Welfare Commission (IWC) wage order and Labor Code statutes. Specifically, Plaintiffs challenged CPS’s policy of failing to compensate the guards for on-call time unless they were required to conduct an investigation. The trial court granted Plaintiffs’ motion for summary adjudication of the declaratory relief complaints, concluding that CPS’s compensation policy violated Wage Order 4. The Court of Appeal affirmed in part and reversed in part. The Supreme Court affirmed in part and reversed in part, holding (1) Plaintiffs’ on-call hours constituted compensable hours worked within the meaning of Wage Order 4 and were subject to the wage order’s minimum wage and overtime provisions; and (2) CPS could not exclude “sleep time” from Plaintiff’s twenty-four-hour shifts. View "Mendiola v. CPS Sec. Solutions" on Justia Law