California employment case index

A Tesla yard hostler who moved 53-foot trailers of out-of-state auto parts around the Fremont factory — never crossing a state line — sued for wage-and-hour violations, and Tesla moved to compel individual arbitration. In the published portion of its opinion, the First District holds yard hostlers are FAA section 1 transportation workers exempt from arbitration, and clarifies which wage claims Labor Code section 229 keeps in court.

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) […]

Ferra v. Loews Hollywood Hotel, LLC (2021) 11 Cal.5th 858 holds that the meal/rest premium under Labor Code § 226.7(c) must be paid at the “regular rate of compensation,” which is synonymous with the overtime “regular rate of pay” and includes all nondiscretionary payments — not just base hourly wages. The holding is retroactive.

Donohue v. AMN Services, LLC (2021) 11 Cal.5th 58 holds that employers may not round meal-period time punches, and that time records showing short, late, or missed meal periods raise a rebuttable presumption of a violation — usable even at summary judgment.

Augustus v. ABM Security Services, Inc. (2016) 2 Cal.5th 257 holds that a compliant rest period must be free of both duties and employer control: an employer may not require employees to remain “on call” during a rest break, even if interruptions rarely occur.

Neither Labor Code section 1194 nor section 218.5 authorizes an award of attorney fees to a party that prevails on a section 226.7 claim; such claims are not actions for the nonpayment of minimum wages or overtime (§1194) and are not the kind of nonpayment-of-wages action that triggers §218.5 fee-shifting, so each…

Brinker Restaurant Corp. v. Superior Court (2012) 53 Cal.4th 1004 is California’s foundational meal-and-rest decision: an employer must provide a duty-free meal period but need not ensure no work is done; it sets the meal-timing and rest-period rules and confirms that courts may resolve merits questions enmeshed with class certification.

The section 226.7 meal/rest payment is a wage (premium pay), not a penalty, and is therefore governed by the three-year statute of limitations applicable to wage claims rather than the one-year period for penalties.

In McDonald v. Santa Fe Trail Transportation Co. (1976) 427 U.S. 273, two white employees were discharged for participating in the theft of antifreeze from a shipment in their employer's care, while a Black employee charged with the same misconduct was retained. The Supreme Court held — unanimously as to Title VII, and seven-to-two as to 42 U.S.C. § 1981 — that both statutes protect against racial discrimination directed at any race, including white persons. An employer “may justifiably refuse to rehire one who was engaged in unlawful, disruptive acts against it, but only if this criterion is applied alike to members of all races.” The judgment dismissing the complaint was reversed and the case remanded.