California employment case index

Inglewood’s elected city treasurer accused the mayor of misappropriating public funds, then saw her monthly salary cut from $8,000 to $1,404 and her duties stripped away. Her whistleblower retaliation suit under Labor Code section 1102.5 failed at the threshold: a unanimous Supreme Court held that elected officials are not “employees” within section 1106’s definition. Finding the statutory text inconclusive, the court rested on legislative history and context — section 1106 protects rank-and-file public workers, not officials who answer to the electorate — while noting that other remedies, including the First Amendment, may remain available.

Tipped employees won preliminary certification of a nationwide FLSA collective in Arizona, and the district court authorised notice to out-of-state servers because one Arizona plaintiff had sued. The Ninth Circuit held that theory wrong, joining four circuits against the First to hold that Bristol-Myers Squibb applies in FLSA collective actions: where jurisdiction is specific, each opt-in plaintiff's claim must bear its own connection to the forum. The panel simultaneously preserved the Campbell two-step and refused to require pre-notice rulings on absent employees' arbitration agreements — a split decision whose wins and losses both reshape forum strategy in hybrid wage cases.

Reversing summary judgment for the UC Regents, the Second District mapped the post-Lawson landscape — Labor Code § 1102.6 governs § 1102.5 claims, Government Code § 8547.10(e) supplies the same framework for University of California whistleblowers, and McDonnell Douglas still governs Health and Safety Code § 1278.5 claims, under which Scheer's clause-by-clause dismantling of his termination letter raised a triable issue of pretext.