California employment case index

A former Work Practice Apprentice at the San Francisco Zen Center won a wage award, but the trial court held the First Amendment’s ministerial exception barred his claims. The First District reverses, adopting its companion case Lorenzo: the exception bars only claims that require resolving ecclesiastical questions, and the Center showed none. NOTE: the controlling ministerial-exception issue is now before the California Supreme Court in Lorenzo (S294565), so this opinion is citable for persuasive value only.

A work practice apprentice at one of North America’s largest Soto Zen Buddhist temples conceded she was a minister, sued only for the minimum and overtime wages she had already earned, and lost on summary judgment to the First Amendment ministerial exception. Division Five of the First District reversed on two independent grounds. The exception, it held, bars only those employment claims that necessarily require an inquiry into matters of a religious entity’s internal government closely linked to its faith and doctrine — and the Center never explained how a minimum-wage claim required one, conceding in its brief that adjudicating the case raised no ecclesiastical question. Separately, because the Labor Commissioner had found two individuals liable as the employer under Labor Code section 558.1, each of them had to post an undertaking under section 98.2 to perfect a de novo appeal; neither did, so the trial court had no jurisdiction over their appeals. The California Supreme Court granted review on February 11, 2026, limited to the ministerial-exception question, but denied depublication and directed that the opinion may still be cited both for its persuasive value and to establish a conflict in authority. This analysis sets out the Court’s own issue statement, what the Court of Appeal actually held and on what evidence, and exactly how much weight the opinion carries while review is pending.

Piece-rate employees are entitled to separate hourly compensation for time spent waiting for repair work or performing other nonrepair tasks directed by the employer during their work shifts; piece-rate earnings cannot be averaged across that nonproductive time to satisfy the minimum-wage obligation (215 Cal.App.4th…

Section 203(b) contains a single, three-year limitations period governing all actions for section 203 penalties, regardless of whether the penalty claim is accompanied by a claim for unpaid final wages; and the penalties may be recovered even though the underlying wages were eventually paid.

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.

Fired the day she returned from pregnancy-related bed rest, a caregiver defeated summary judgment with declarations from four coworkers describing pregnancy-triggered firings by the same supervisors — evidence the court held admissible as a matter of law to prove motive, not propensity.

“Discharge” under sections 201 and 203 includes not only firing but also releasing an employee upon completion of the particular job assignment or time duration for which he or she was hired; final wages are then immediately due, and a willful failure to pay triggers waiting-time penalties.

California does not permit wage averaging: the minimum-wage standard applies to each hour worked, and an employer must pay at least the minimum wage for every compensable hour; it cannot use higher pay for some hours to offset unpaid or sub-minimum hours.

FEHA never names leave as a reasonable accommodation, yet leave is the most common accommodation dispute in practice. Two published decisions supply both halves of the rule: Hanson v. Lucky Stores holds that a finite leave can be a reasonable accommodation where the employee is likely to be able to work at the end of it, and that an employer need not wait indefinitely; Jensen v. Wells Fargo Bank fixes what an employer must establish to end such a case on summary judgment. This analysis states the rule, the proviso, the indefiniteness limit and the duty to reassign, and corrects the subdivision lettering that briefs still get wrong.

When Lillian Garland returned from pregnancy disability leave to find her receptionist job filled, California’s guarantee of leave and reinstatement collided with her employer’s theory that Title VII forbade treating pregnancy “better” than other disabilities. The Supreme Court sided with California: the Pregnancy Discrimination Act is a floor beneath which pregnancy benefits may not drop, not a ceiling above which states may not rise — and employers can always comply with both laws by leveling benefits up. Guerra remains the constitutional foundation of the PDLL and of every California pregnancy protection built since.