The Review · Case Index

California employment case index

Search every indexed California wrongful-termination and employment decision, or browse by subject area, statute, and decade — each summary source-verified against the published reporter.

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1 case

Stone v. Alameda Health System: Public-Entity Employers Are Not Subject to PAGA (or Most Labor Code Wage Rules)

August 15, 2024
Two Highland Hospital workers sued the public hospital authority running Alameda County’s medical facilities for meal-and-rest violations, unpaid wages, and PAGA penalties. A unanimous Supreme Court ended the case at the definitions: Labor Code section 18’s “person” — the term that controls who is an “employer” under the wage order and who can be penalized under PAGA — affirmatively excludes public entities. Absent express words bringing the government in, break rules and PAGA penalties stop at the public-sector line. The court disapproved Sargent’s contrary rule for statutes carrying their own penalties, declined to decide whether Government Code section 818 independently bars such penalties, and reserved the effect of the 2024 PAGA reform.