Calif. Supreme Court Finds Federal 'De Minimis' Rule Doesn't Apply to California Wage Laws
In a win for California employees, the court said state law doesn't recognize a rule that federal courts often apply when dismissing wage claims for small amounts of time that are difficult to track.
July 26, 2018 at 01:47 PM
5 minute read
In a unanimous opinion, California's high court found that the state's wage-and-hour laws don't endorse a rule that federal courts often apply to excuse businesses' failure to pay wages for small amounts of time that are difficult to track.
“There is no indication in the text or history of the relevant statutes and Industrial Welfare Commission (IWC) wage orders of such adoption” of the so-called “de minimis” doctrine, wrote Justice Goodwin Liu, in a 21-page opinion joined by his six colleagues.
“An employer that requires its employees to work minutes off the clock on a regular basis or as a regular feature of the job may not evade the obligation to compensate the employee for that time by invoking the de minimis doctrine,” he wrote.
The ruling came in the closely watched case of Douglas Troester, a former Starbucks shift supervisor who sued Starbucks in state court in 2012, claiming the company violated the California Labor Code because it failed to pay him for time he spent closing the store where he worked.
Troester claimed that after clocking out he still was required to upload store sales data, turn off computers and lights, lock up, activate the store alarm, escort employees to their cars or wait with them for their rides, and occasionally put away patio furniture that had been left outside. The case was removed to federal court where Troester lost on summary judgment.
On appeal, the U.S. Court of Appeals for the Ninth Circuit referred the case to the California Supreme Court to determine whether the de minimis defense, which Starbucks won on at the district court, applied under California law.
“Nothing in the language of the wage orders or Labor Code shows an intent to incorporate the federal de minimis rule articulated in [the case law] or the federal regulation,” Liu wrote.
The decision noted that Troester's unpaid time totaled about 12 hours and 50 minutes over 17 months. At $8 per hour, that time amounted to about $102.67 before penalties.
“That is enough to pay a utility bill, buy a week of groceries, or cover a month of bus fares,” Liu wrote. “What Starbucks calls 'de minimis' is not de minimis at all to many ordinary people who work for hourly wages.”
Stanley Saltzman of Marlin & Saltzman, who argued on behalf of Troester at the state's high court, pointed to that passage in saying that he was “overwhelmed” by the decision.
“We are heartened that employers are now being told, very clearly, that they cannot require their workers to regularly perform minutes per day of unpaid labor,” he added in an email shortly after the decision was handed down.
Starbucks' counsel, Rex Heinke of Akin Gump Strauss Hauer & Feld, referred a request for comment to the company. A Starbucks representative said the company was “disappointed” by the decision and “will await further disposition of the case before the 9th circuit as the appeal process continues.”
Kirstin Muller, a management-side employment litigator at Hirschfeld Kraemer in Los Angeles, said though the case didn't specifically address employers with policies of rounding employees' time up or down, those employers should take note. She said employers should make sure they are rounding to the smallest time increment possible and conducting regular audits to make sure that employees aren't bearing the brunt of those policies.
Muller added that there “is still some hope” for employers in the decision, particularly in a concurrence from Justice Leondra Kruger, which said that there had to be some “rule of reason” to avoid forcing employers to track every fraction of a second of employee time.
“I still think there are arguments for employers that if it really is a small and discrete period of time that is difficult to capture or is pretty irregular, that there are arguments that some sort of de minimis rule could apply in California,” Muller said. She also noted that the decisions “could lead to more cultural changes” in workplaces, with employers more strictly tracking that employees are working once they clock in.
In a separate concurrence to Thursday's decision, Justice Mariano-Florentino Cuéllar wrote that the court should avoid any future holding causing employers to adopt intensive employee monitoring that “might systematically erode employees' ability to find even a moment of privacy in their lives.”
Read the decision below:
Read more:
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View All'Nothing Is Good for the Consumer Right Now': Experts Weigh Benefits, Drawbacks of Updated Real Estate Commission Policies
Federal Judge Denies Build-A-Bear Workshop's Motion to Dismiss 'Squishmallow' Copyright Infringement Suit
Trending Stories
- 1Elon Musk Names Microsoft, Calif. AG to Amended OpenAI Suit
- 2Trump’s Plan to Purge Democracy
- 3Baltimore City Govt., After Winning Opioid Jury Trial, Preparing to Demand an Additional $11B for Abatement Costs
- 4X Joins Legal Attack on California's New Deepfakes Law
- 5Monsanto Wins Latest Philadelphia Roundup Trial
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250