California employment case index

In Naranjo II (2024) 15 Cal.5th 1056, the California Supreme Court holds that an employer’s objectively reasonable, good-faith belief that its wage statements complied with the law defeats both Labor Code § 226 penalties (no “knowing and intentional” violation) and § 203 waiting-time penalties (no “willful” failure) — harmonizing the two penalty statutes around a common good-faith defense.

Naranjo v. Spectrum Security Services, Inc. (Naranjo I)Premium pay owed for missed meal and rest breaks under Labor Code section 226.7 constitutes “wages,” so it must be reported on wage statements under section 226 and is subject to waiting-time penalties under section 203 when not timely paid at separation.Naranjo v. Spectrum Security Services, Inc. (2022) […]

The Supreme Court’s foundational “cat’s paw” decision: an employer is liable when a biased supervisor performs an act intended to cause an adverse employment action that is a proximate cause of the ultimate decision — even if the formal decisionmaker had no discriminatory animus. A decisionmaker’s “independent investigation” does not automatically break the causal chain, especially when it credits the biased actor’s report without independently confirming the action was justified.

Reeves v. Sanderson Plumbing Products, Inc. A plaintiff’s prima facie case combined with sufficient evidence that the employer’s stated reason is false can, without more, sustain a finding of intentional discrimination. Reeves v. Sanderson Plumbing Products, Inc. (2000) 530 U.S. 133 Parallel citations: 120 S.Ct. 2097; 147 L.Ed.2d 105. Supreme Court of the United States. […]

In McKennon v. Nashville Banner Publishing Co. (1995) 513 U.S. 352, a 62-year-old secretary discharged in what the employer conceded for summary-judgment purposes was age discrimination admitted in deposition that she had copied confidential company documents during her final year. The lower courts held this after-acquired evidence barred all ADEA relief. A unanimous Supreme Court, per Justice Kennedy, reversed. Such evidence does not bar liability — the ADEA violation that prompted the discharge cannot be disregarded — but it bears on the remedy: as a general rule it forecloses reinstatement and front pay, and back pay runs only from the date of the unlawful discharge to the date the employer discovered the wrongdoing. And the employer must first prove the wrongdoing was so severe that it would in fact have discharged the employee on that ground alone.

In Western Air Lines, Inc. v. Criswell (1985) 472 U.S. 400, the Supreme Court adopted the two-part age-BFOQ test for the Age Discrimination in Employment Act: the age limit must be reasonably necessary to the essence of the employer's business, and the employer must show either reasonable cause to believe that all or substantially all older workers cannot perform the job safely or that it is impossible or highly impractical to assess older employees individually. The Court rejected a deferential “rational basis” standard.