California employment case index

A trucking-job applicant brought an FCRA class action over confusing, noncompliant background-check disclosure forms; after Limon v. Circle K required concrete injury, the trial court decertified the class. The First District reverses and declines to follow Limon: California courts are not bound by Article III, and a willful FCRA violation supports statutory damages of $100–$1,000 and standing without proof of harm.

A solar-project electrician queued unpaid at a security gate while guards inspected vehicles, drove miles of access road under strict site rules, and ate lunch confined to a designated area under a CBA calling meal periods “unpaid.” Answering the Ninth Circuit, a unanimous Supreme Court held the exit procedure is compensable “hours worked”; the gate-to-lot drive is compensable only as “employer-mandated travel,” and only if the gate is the first location required for a reason beyond site access; and no collective bargaining agreement can waive the minimum wage for a meal period during which the employer’s confinement forecloses otherwise feasible personal activities.

Three different doctrines collide in public-sector termination cases, and collapsing them is the most expensive mistake in this corner of California employment law. Exhaustion of administrative remedies is a prerequisite to suing at all. Exhaustion of judicial remedies is the separate Westlake requirement that an employee who has already lost before a personnel board overturn that decision by administrative mandamus under Code of Civil Procedure section 1094.5 before suing on the same facts. And collateral estoppel is what happens if the employee does not: the agency's findings become final and bind. Johnson v. City of Loma Linda extended the rule to FEHA while holding it inapplicable to Title VII, Page applied it on demurrer, and Skelly supplies the due-process floor the agency hearing must meet. This analysis keeps the three apart, states what each anchor actually held and how it was disposed of, and sets out the sequencing obligation a practitioner owes a public-employee client at intake.