This case stemmed from the DLSE's investigation into whether Brinker was complying with its obligations to provide rest and meal breaks to its employees, maintain proper records, and pay premium wages in the event required breaks were not provided. The court considered on appeal issues of significance to class actions generally and to meal and rest break class actions in particular. The court concluded that the trial courts were not obligated as a matter of law to resolve threshold disputes over the elements of a plaintiff's claims, unless a particular determination was necessarily dispositive of the certification question. Because the parties have so requested, however, the court nevertheless addressed several threshold disputes. In regards to the nature of an employer's duty to provide meal periods, the court concluded that an employer's obligation was to relieve its employee of all duty, with the employee thereafter at liberty to use the meal period for whatever purpose he or she desired, but the employer need not ensure that no work was done. Further, in light of the substantial evidence submitted by plaintiffs of defendants' uniform policy, the court concluded that the trial court properly certified a rest break subclass. On the question of meal break subclass certification, the court remanded to the trial court for reconsideration. With respect to the third contested subclass, covering allegations that employees were required to work "off-the-clock," no evidence of common policies or means of proof was supplied, and the trial court therefore erred in certifying a subclass. View "Brinker Restaurant Corp. v. Super. Ct. of San Diego Cty" on Justia Law
Plaintiffs, claims adjusters employed by defendants, filed four class action lawsuits alleging defendants erroneously classified them as exempt "administrative" employees, seeking damages based on unpaid overtime work. At issue was whether plaintiffs were exempt employees, not entitled to overtime compensaution under the Labor Code and regulations of the California Industrial Welfare Commission (IWC). The court held that the Court of Appeal misapplied the substantive law when its analysis focused on Wage Order 4. The court held that, in resolving whether work qualified as administrative, courts must consider the particular facts before them and apply the language of the statutes and wage orders at issue. Only if those sources failed to provide adequate guidance, was it appropriate to reach out to other sources. Accordingly, the court reversed and remanded. View "Harris v. Super. Ct." on Justia Law
Plaintiff, a resident of Los Angeles, filed a class action lawsuit on behalf of himself and similarly situated individuals challenging the city's telephone users tax (TUT) and seeking refund of funds collected under the TUT over the previous two years. At issue was whether the Government Code section 910 allowed taxpayers to file a class action claim against a municipal government entity for the refund of local taxes. The court held that neither Woosley v. State of California, which concerned the interpretation of statutes other than section 910, nor article XIII, section 32 of the California Constitution, applied to the court's determination of whether section 910 permitted class claims that sought the refund of local taxes. Therefore, the court held that the reasoning in City of San Jose v. Superior Court, which permitted a class claim against a municipal government in the context of an action for nuisance under section 910, also permitted taxpayers to file a class claim seeking the refund of local taxes under the same statute. Accordingly, the court reversed and remanded the judgment of the Court of Appeals.
Posted in: California Supreme Court, Class Action, Communications Law, Constitutional Law, Government & Administrative Law, Tax Law