California employment case index

A firm filed a wage-and-hour class action duplicating one it had already filed elsewhere, then opposed a stay with a brief — drafted by a contract attorney using generative AI — full of nonexistent citations and at least eight fabricated quotations. The First District affirms $6,000 in section 128.7 sanctions: counsel of record bear ultimate responsibility for what they sign, and the duty to verify authority cannot be delegated to any form of technology.

Citigroup let employees take part of their annual compensation as discounted restricted stock vesting only after two years; an employee who resigned early forfeited both the shares and the pay used to buy them. The California Supreme Court affirmed summary judgment for the company, holding that no earned wages remained unpaid on resignation. The decision agrees that restricted stock is a wage – so it turns on when incentive compensation is earned, not on characterization – and expressly refuses to extend Suastez's pro rata vacation-vesting rule to voluntary incentive programs.

Nine days after Fatmeh Badih told her employer — a physician with fewer than five employees — that she was pregnant, her last day was set; the DFEH would not even accept her complaint because the office was too small for the FEHA. Division One of the First District affirmed her wrongful-discharge verdict anyway, holding that pregnancy discrimination is a form of sex discrimination under article I, section 8 of the California Constitution, whose fundamental public policy against sex discrimination in employment binds every employer regardless of size. Jennings v. Marralle was distinguished, not disturbed: age has no constitutional anchor, but sex — and therefore pregnancy — does. Badih remains the pleading answer for pregnancy discharges at California's smallest workplaces.