Justia California Supreme Court Opinion Summaries

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

A male supervisor employed by a franchisee allegedly subjected a female subordinate to sexual harassment while working together at the franchisee’s pizza store. Plaintiff, the victim, sued the franchisor, the franchisee, and the harasser, arguing that the franchisor could be held vicariously liable for the harasser’s misconduct. The trial court granted summary judgment in favor of the franchisor, concluding that the requisite employment and agency relationship did not exist between the franchisor and franchisee in this case. The court of appeals reversed. The Supreme Court reversed and granted summary judgment in the franchisor’s favor, holding that, under the circumstances of this case, the franchisor did not stand in an employment or agency relationship with the franchisee and its employees for purposes of holding it vicariously liable for workplace injuries allegedly inflicted by the victim's supervisor. View "Patterson v. Domino’’s Pizza, LLC " on Justia Law

The People filed a complaint against Defendants, Pac Anchor Transportation, Inc. (Pac Anchor) and Alfredo Barajas, for violating the unfair competition law (UCL), alleging that Defendants misclassified drivers as independent contractors and committed other violations of California’s labor and unemployment insurance laws. The trial court granted judgment on the pleadings in Defendants’ favor, determining that the Federal Aviation Administration Authorization Act of 1994 (FAAAA) preempted the People’s action. The court of appeals reversed, concluding that because the People’s UCL action was not related to Pac Anchor’s price, route, or service as a motor carrier, the FAAAA did not preempt this action against Defendants. After noting that the FAAAA does not preempt generally applicable employment laws that affect prices, routes, and services, the Supreme Court affirmed, holding that the FAAAA did not preempt the People’s UCL action against Defendants in this case, as the UCL action was independent of Defendants’ price, routes, or services with respect to the transportation of property. View "People ex rel. Harris v. Pac Anchor Transp., Inc." on Justia Law

Plaintiff, who formerly worked for Time Warner Cable, Inc. as a commissioned salesperson, filed a class action suit against Time Warner, alleging wage and hour violations. Time Warner paid Plaintiff through biweekly paychecks, which included hourly wages in every pay period and commission wages approximately every other pay period. Time Warner removed the matter to federal court and sought summary judgment. The district court granted summary judgment, concluding that Time Warner could attribute commission wages paid in one biweekly pay period to other pay periods for the purpose of satisfying California’s compensation requirements. The Court of Appeals for the Ninth Circuit’s asked the Supreme Court to consider the issue. The Supreme Court answered the Ninth Circuit’s question in the negative, holding that an employer may not attribute commission wages paid in one pay period to other pay periods in order to satisfy California’s compensation requirements. View "Peabody v. Time Warner Cable, Inc." on Justia Law

An employee (Claimant) was asked by his employer to sign a written disciplinary notice regarding Claimant’s alleged misconduct. Claimant refused to sign the notice, claiming that he wished to consult with his union first and that he believed that signing would constitute an admission of guilt. Based on this incident, the employer terminated Claimant for insubordination. The Employment Development Department denied Claimant’s application for unemployment benefits, determining that Claimant’s refusal to sign the disciplinary notice constituted misconduct. The Unemployment Insurance Appeals Board reversed, finding that Claimant’s failure to sign the notice was “an instance of poor judgment” that did not disqualify Claimant from receiving benefits. The Supreme Court affirmed, holding that, even if Claimant’s refusal to sign the disciplinary notice justified his termination, Claimant did not commit misconduct within the meaning of California’s Unemployment Insurance Code. View "Paratransit, Inc. v. Unemployment Ins. Appeals Bd." on Justia Law