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) […]

A unanimous Supreme Court holds that a signed offer letter stating employment is "at will" and terminable "at any time" is unambiguous — recruitment talk of a "long-term fix" cannot create an implied for-cause contract or support fraud reliance — with Justice Baxter (joined by Corrigan) urging reconsideration of Pacific Gas and Justice Moreno reserving "upon notice" clauses.

Guz v. Bechtel National, Inc. The at-will presumption can be overcome by an implied-in-fact contract to discharge only for good cause, judged on the totality of the relationship — but the implied covenant of good faith and fair dealing cannot impose substantive limits beyond the agreement’s actual terms, and a FEHA discrimination claim must survive […]

The Tameny claim failed because Foley’s report about a coworker served the employer’s private interest, not a fundamental public policy. Foley nonetheless adequately pleaded an implied-in-fact contract to discharge only for good cause — based on longevity of service, promotions, raises, assurances, and the employer’s…

Yes. The longevity of Pugh’s service, together with the employer’s commendations and assurances and its acknowledged practices, supported an implied-in-fact promise that he would not be discharged except for good cause; the nonsuit was therefore error and the judgment was reversed (id. at p. 330).