Justia California Supreme Court Opinion Summaries

An Employee filed a class action complaint against his Employer. The Employee, however, had entered into an arbitration agreement with his Employer that waived his right to class proceedings. The Employee also sought to bring a representative action under the Labor Code Private Attorneys General Act (PAGA). The Court of Appeal concluded that the entire arbitration agreement, which included a PAGA waiver, should be enforced. The Supreme Court reversed, holding, as regards the class action complaint, (1) a state law that restricts enforcement of the waiver of the right to class proceedings in arbitration agreements on grounds of public policy or unconscionability is preempted by the Federal Arbitration Act (FAA); but (2) the class action waiver at issue in this case was unlawful under the National Labor Relations Act, and the Employer waived its right to arbitrate. With regard to the PAGA action, the Court held (1) the FAA does not preempt a state law that prohibits waiver of PAGA representative actions in an employment contract; and (2) an arbitration agreement requiring an employee to give up the right to bring representative PAGA actions is contrary to public policy and unenforceable as a matter of state law. View "Iskanian v. CLS Transp. Los Angeles, LLC" on Justia Law

Loan officers for U.S. Bank National Association (USB) sued USB for unpaid overtime, asserting that they made been misclassified as exempt employees under the outside salesperson exemption. The trial court certified a class of plaintiffs and then determined the extent of USB’s liability to all class members by extrapolating from a random sample. The jury returned a verdict of approximately $15 million, resulting in an average recovery of more than $57,000 per person. The court of appeal reversed the trial court’s judgment and ordered the class decertified. The Supreme Court affirmed the court of appeal’s judgment in its entirety, holding that the trial court’s particular approach to sampling in this case was profoundly flawed and prevented USB from showing that some class members were entitled to no recovery. Remanded for a new retrial on both liability and restitution. View "Duran v. U.S. Bank Nat’l Ass’n" on Justia Law

Plaintiff, a hospital staff physician, claimed the hospital’s decision to terminate his staff privileges was an act of retaliation for his reports of substandard performance by hospital nurses and thus a violation of Cal. Health & Safety Code 1278.5. Defendants moved to dismiss on grounds that Plaintiff could not bring a civil suit under section 1278.5 unless he first succeeded by mandamus in overturning the hospital’s action. The appellate court held that Plaintiff could pursue his claims based on section 1278.5 even though he had not previously sought and obtained a mandamus judgment against the hospital’s decision. The Supreme Court affirmed, holding that a physician’s claim that a hospital decision to restrict or terminate his or her staff privileges was an act of retaliation for his or her whistleblowing in furtherance of patient care and safety need not seek and obtain a mandamus petition to overturn the decision before filing a civil action under section 1278.5. View "Fahlen v. Sutter Cent. Valley Hosps." on Justia Law

At issue in this case was the section of the Labor Code (article 2.3) that establishes a process for employees who dispute the diagnosis or treatment provided by a medical provider network (MPN). Petitioner was injured when she fell at work. Petitioner began treatment with a physician in Employer's MPN, but later undertook treatment with a doctor outside the network, Dr. Nario. Thereafter, Petitioner applied for temporary disability benefits, relying on reports by Dr. Nario. Employer argued that reports from non-MPN doctors were inadmissible under Cal. Labor Code 4616.6, an article 2.3 provision, for purposes of the disability hearing. The workers' compensation judge (WCJ) overruled the objection, concluding that reports from all treating doctors were admissible. The Workers' Compensation Appeals Board (Board) rescinded the WCJ's decision, holding that section 4616.6 precluded the admission of reports from any doctor outside the MPN. The court of appeal annulled the Board's decisions. The Supreme Court affirmed, holding that section 4616.6 restricts the admission of medical reports only in proceedings under article 2.3 to resolve disputes over diagnosis and treatment within an MPN. View "Valdez v. Workers' Comp. Appeals Bd." on Justia Law

After declaring a fiscal emergency, the City of Los Angeles adopted a mandatory furlough program for its civilian employees. Many of those employees that were represented by a union (Union) filed grievances against the City, contending that the furloughs violated memorandums of understanding (MOUs) governing the terms and conditions of their employment. The grievances were denied, and the City denied the employees' request to arbitrate. The superior court subsequently granted the Union's petition for an order compelling the City to arbitrate the dispute. The court of appeal granted the City's petition for a writ of mandate, concluding that the City could not be compelled to arbitrate under the terms of the MOUs because arbitration would constitute an unlawful delegation to the arbitrator of discretionary policymaking powers that the City's charter vested in its city council. The Supreme Court reversed, holding (1) arbitration of the employee furlough dispute did not constitute an unlawful delegation of discretionary authority to the arbitrator; and (2) the City was contractually obligated to arbitrate the dispute. View "City of Los Angeles v. Superior Court" on Justia Law

Doctor applied for reappointment to Hospital's medical staff. Hospital denied the application. Doctor requested a review hearing to challenge the decision. Under Hospital's bylaws, Hospital's Medical Executive Committee (MEC) was responsible for selecting the hearing officer and panel members that would hear Doctor's claim. However, the MEC declined to exercise its authority, leaving the responsibility to Hospital's Governing Board. After a hearing, the Judicial Review Committee (JRC) concluded that the Governing Board's decision to deny Doctor's application for reappointment was reasonable. The Governing Board subsequently ordered that Doctor be terminated from the medical staff. Doctor filed an administrative mandate petition, asserting, among other claims, that he had been denied a fair proceeding because the Governing Board, rather than the MEC, had chosen the members of the JRC for his judicial review hearing. The court of appeal held that Doctor had been deprived of his right to a fair procedure and was entitled to a new judicial review hearing. The Supreme Court reversed, holding that the court of appeals incorrectly concluded that the MEC's delegation of the power to select the participants in the JRC was a material violation of Hospital's bylaws. Remanded. View "El-Attar v. Hollywood Presbyterian Med. Ctr." on Justia Law

The Service Employees International Union, Local 721 (SEIU) was the exclusive bargaining representative of all Los Angeles County employees. SEIU proposed amending the memorandum of understanding it had with the County's bargaining units to enable SEIU to obtain the home addresses and phone numbers of all represented employees, including those who had not joined the union. The County rejected the amendment. The Los Angeles County Employee Relations Commission concluded that the County's refusal to provide the contact information was an unfair labor practice. The superior court denied the County's petition for relief. The appellate court affirmed but held that nonmember employees were entitled to notice and an opportunity to opt out before their contact information could be disclosed to SEIU. The Supreme Court affirmed but reversed the court of appeal's imposition of procedural requirements limiting disclosure, holding (1) although the County's employees have a cognizable privacy interest in their home addresses and telephone numbers, the balance of interests strongly favors disclosure of this information to the union that represents them; and (2) procedures may be developed for employees who object to this disclosure, but the court of appeal exceeded its authority by attempting to impose specific procedures on the parties. View "County of Los Angeles v. Los Angeles County Employee Relations Comm'n" on Justia Law

The City fired Plaintiff, a bus driver, for allegedly poor job performance. Plaintiff brought this action against the City, alleging she was fired because of her pregnancy in violation of the Fair Employment and Housing Act (FEHA). During trial, the City requested the court to instruct the jury that if it found a mix of discriminatory and legitimate motives, the City could avoid liability by proving that a legitimate motive alone would have led it to make the same decision to fire Plaintiff. The trial court refused the instruction, and the jury returned a verdict for Plaintiff. The court of appeal reversed, concluding that the refusal to give the requested instruction was prejudicial error. The Supreme Court affirmed the court of appeal's judgment overturning the damages verdict in this case and remanded, holding (1) under the FEHA, when a jury finds that unlawful discrimination was a substantial factor motivating a termination of employment, and when the employer proves it would have made the same decision absent such discrimination, a court may not award damages, backpay, or an order of reinstatement; but (2) Plaintiff in this circumstance could still be awarded, where appropriate, declaratory relief or injunctive relief to stop discriminatory practices. View "Harris v. City of Santa Monica" on Justia Law

After a labor union began picketing on a supermarket's privately owned walkway in front of the store's customer entrance, the supermarket owner sought a court injunction to prevent the picketing. The owner argued that because the union was using the walkway for expressive activity without complying with the supermarket's regulations, the union was trespassing on its property. The trial court denied relief, concluding that the supermarket owner had failed to satisfy Cal. Lab. Code 1138.1's requirements for obtaining an injunction against labor picketing. The court of appeal reversed, holding (1) the walkway was not a public forum, and therefore, the store owner could regulate speech in that area; and (2) both the Moscone Act and section 1138.1 violate free speech and equal protection because they give speech regarding a labor dispute greater protection that speech on other subjects. The Supreme Court reversed and remanded, holding (1) a union's picketing activities in the supermarket's privately owned entrance area do not have state constitutional protection; (2) however, those picketing activities do have statutory protection under the Moscone Act and section 1138.1; and (3) these statutory provisions do not violate the federal constitutional prohibition on content discrimination in speech regulations. View "Ralphs Grocery Co. v. United Food & Commercial Workers Union Local 8" on Justia Law

Cal. Lab. Code 4558 contains a power press exception to the general rule that workers' compensation is the exclusive remedy of an injured worker against the employer. Employee was injured while operating a power press without a point of operation guard. Employee and his wife (Spouse) brought a civil suit against Employer under the power press exception that included a claim for loss of consortium on behalf of Spouse, predicated on the facts allegedly establishing a section 4558 violation. The trial court sustained Employer's demurrer to all of Spouse's causes of action except her claim for loss of consortium. The court of appeal disagreed with the trial court, concluding Spouse could plead a claim for damages for loss of consortium because such a claim fell outside the workers' compensation laws and hence was not barred by the exclusivity rule. The Supreme Court (1) reversed the portion of the judgment of the court of appeal as to Spouse's consortium claim, holding that where the worker's power press injuries do not prove fatal, the Legislature has restricted standing to bring the action at law authorized under section 4558 to the injured worker alone; and (2) affirmed in all other respects. Remanded. View "LeFiell Mfg. Co. v. Superior Court" on Justia Law