California employment case index

The unpaid-wages component of section 558 is not a civil penalty recoverable through PAGA; only the fixed civil penalties ($50/$100 per employee per pay period) are PAGA penalties. Because the unpaid wages are not part of the PAGA claim, the trial court could not compel that portion to arbitration as if it were.

The Supreme Court’s foundational “cat’s paw” decision: an employer is liable when a biased supervisor performs an act intended to cause an adverse employment action that is a proximate cause of the ultimate decision — even if the formal decisionmaker had no discriminatory animus. A decisionmaker’s “independent investigation” does not automatically break the causal chain, especially when it credits the biased actor’s report without independently confirming the action was justified.

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.

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.