The federal appeals court that oversees cases arising from California recently handed down an opinion that provides guidance to employers trying to comply with collective bargaining agreements (CBAs) while simultaneously being challenged to apply potentially inconsistent definitions in California’s overtime law. The U.S. Court of Appeals for the Ninth Circuit’s Jan. 29 decision in Curtis v. Irwin Industries handed a victory to the employer in question, though this does not necessarily provide employers with an automatic reprieve from state law.

The Framework: Pre-emption Should Be Narrowly Applied

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