News & Analysis as of

Unpaid Wages Private Attorneys General Act (PAGA) Labor Code

Constangy, Brooks, Smith & Prophete, LLP

Massachusetts employers: Proposed private attorney general act for wage-hour claims is a major concern

For the third consecutive legislative session, Massachusetts state representative Tram T. Nguyen (D-Essex) has proposed a bill (H.1916) to establish a private right of action by employees on behalf of themselves, their fellow...more

CDF Labor Law LLP

Furloughs Trigger Employer’s Obligation To Pay Final Wages Immediately

CDF Labor Law LLP on

A recent Ninth Circuit panel held that Hyatt employees who were “laid off” in March 2020 were entitled to payment of their accrued vacation time immediately, even though the employees were not officially terminated until June...more

Best Best & Krieger LLP

Best in Law: Remote Working Laws for Calif. Employers

BB&K Attorneys Damian Moos and Kandice Kim Write About What Employers Should Know in the Southern Calif. Newspaper Group - In response to state and local COVID-19 stay at home orders, many California employers...more

Hinshaw & Culbertson LLP

The 12 Days of California Labor & Employment Series – Day 10: Civil Penalties for Unpaid Wages

Hinshaw & Culbertson LLP on

It’s the end of the year and while everyone is busy, employers in California should be aware of new laws and regulations that go into effect on January 1, 2020. In the spirit of the season, we are using the next “12 days of...more

Proskauer - California Employment Law

California Employment Law Notes - November 2019

Court Upholds Whistleblower Verdicts In Favor Of Fired Parking Ticket Hearing Examiners - Hawkins v. City of Los Angeles, 40 Cal. App. 5th 384 (2019) - Todd Hawkins and Hyung Kim were terminated from their jobs as...more

Orrick - Employment Law and Litigation

No Unpaid Wages Under PAGA

On September 12, 2019, the California Supreme Court issued its decision in ZB, N.A. v. Superior Court, which resolved a split of authority regarding whether an employer may compel arbitration of an employee’s Private...more

Polsinelli

Good News, for a Change, for California Employers in Connection with Wage and Hour Cases

Polsinelli on

The Courts were kind to California employers in September, 2019, issuing two decisions which substantially reduce the damages which plaintiffs can recover in wage and hour cases. ...more

Holland & Knight LLP

California Supreme Court Confirms Unpaid Wages Not Recoverable as "Civil Penalties" Under PAGA

Holland & Knight LLP on

In ZB, N.A., and Zions Bancorporation v. Superior Court of San Diego County, No. S246711, __ Cal. 5th __, 2019 WL 4309684 (Cal. 2019) (ZB), the California Supreme Court held on Sept. 12, 2019, that California's Labor Code...more

Fox Rothschild LLP

CA Supreme Court Cuts Back On PAGA Recovery

Fox Rothschild LLP on

In a departure from decisions in recent years, the California high court has finally imposed some limits on the otherwise expansive reach of the Private Attorneys General Act, Labor Code § 2698, et seq. (“PAGA”). The...more

Littler

California Supreme Court Rules that the “Underpaid Wages” Component of Labor Code Section 558 is Not a Civil Penalty under PAGA

Littler on

In ZB, N.A. v. Superior Court of San Diego County (Lawson), the California Supreme Court held that unpaid wages are not civil penalties under California Labor Code section 558 and are therefore outside the reach of...more

Davis Wright Tremaine LLP

California Supreme Court Limits Scope of Recovery Under PAGA

On September 12, 2019, the California Supreme Court in ZB, N.A. v. Superior Court (Lawson) held that unpaid wages under Labor Code Section 558 are not recoverable under the Private Attorneys General Act (PAGA). ...more

Seyfarth Shaw LLP

PAGA Claims Limited to Recovery of Civil Penalties

Seyfarth Shaw LLP on

Seyfarth Synopsis: The California Supreme Court has held that an individual may not seek unpaid wages under Labor Code section 558. Section 558 can be invoked only by the Labor Commissioner or by an individual suing under...more

Cozen O'Connor

California Employers Cheer Rare PAGA Victory

Cozen O'Connor on

The California Supreme Court recently handed down an increasingly rare win for employers and the defense bar with its September 12 decision in Z.B., N.A. and Zions Bancorporation v. Supreme Court (Lawson) holding that private...more

Akin Gump Strauss Hauer & Feld LLP

California Supreme Court Holds That Unpaid Wages Are Not Recoverable Under PAGA

• On September 12, 2019, in ZB, N.A. v. Superior Court (Lawson), Case No. S246711, the California Supreme Court held the Private Attorneys General Act (PAGA) does not allow recovery of unpaid wages under Labor Code Section...more

Mintz - Employment Viewpoints

California Supreme Court Delivers PAGA Win for Employers

In a significant victory for California employers who use arbitration agreements, the California Supreme Court ruled (ZB, N.A. et al. v. Superior Court of San Diego County, S246711 (September 12, 2019)) that the recovery of...more

Proskauer - California Employment Law

California Supreme Court Hands Employers A Rare Victory, Trims Bloated PAGA Claims

Yesterday September 12, 2019, the California Supreme Court held that private litigants may not recover unpaid wages under the Labor Code Private Attorneys General Act (“PAGA”).  See ZB, N.A. v. Superior Court (Lawson) (Cal....more

Jackson Lewis P.C.

California Supreme Court Rejects Claim For Unpaid Wages Under PAGA

Jackson Lewis P.C. on

Putting an end to employees’ backdoor attempts to recover unpaid wages in Private Attorneys General Act-only actions under California Labor Code Section 558, the California Supreme Court has ruled against allowing such...more

Weintraub Tobin

The California Supreme Court Clarifies Wages Are NOT Part Of The “Civil Penalty” Under Labor Code Section 558 In A PAGA Action

Weintraub Tobin on

On September 12, 2019, the California Supreme Court issued it decision in ZB, N.A., and Zions Bancorporation v. Superior Court [Lawson, real party in interest] (“Lawson”). In analyzing whether the Plaintiff’s lawsuit could...more

BakerHostetler

CA Supreme Court Rules That Employees Cannot Recover Unpaid Wages Through PAGA

BakerHostetler on

California’s Supreme Court has cut off an area of significant potential exposure for California employers by ruling that employees cannot recover unpaid wages on behalf of themselves and other aggrieved employees through...more

Polsinelli

Individual Employees Can Be Liable For Civil Penalties And Attorneys’ Fees For A Company’s Failure To Pay Overtime And/Or Minimum...

Polsinelli on

Notwithstanding two previous California Supreme Court decisions which essentially held that “[u]nder the common law, corporate agents acting within the scope of their agency are not personally liable for the corporate...more

Snell & Wilmer

Subcontractor Wages: Closing the Loopholes

Snell & Wilmer on

This year California ushered in a new law effective January 1, 2018 for private works construction contracts, California’s Labor Code section 218.7. The law applies to all direct contractors who make or take the contract in...more

Fisher Phillips

Glimmers of Hope? Pair of Recent PAGA Cases Provide Rare Procedural Victories for California Employers

Fisher Phillips on

If you’re a California employer, perhaps no single law strikes fear into your heart quite as much as the Labor Code Private Attorneys General Act of 2004 (PAGA). PAGA allows individual “aggrieved employees” to bring...more

Sheppard Mullin Richter & Hampton LLP

Court Of Appeal Holds That Claims To Recover Wages Under Labor Code Section 558 Brought Through The Private Attorneys General Act...

In Esparza v. KS Industries, L.P., 2017 WL 3276363 (2017), the Fifth District Court of Appeal recently clarified the arbitrability of certain claims brought under the Private Attorneys General Act (“PAGA”). Previously, in...more

Mintz - Employment Viewpoints

Another Chapter in California’s PAGA Saga

Sounds like something our favorite attorney Bob Loblaw would be part of. In reality, the PAGA SAGA (for those of you without California employees) relates to PAGA, the acronym for California’s Private Attorneys’ General Act,...more

Wilson Sonsini Goodrich & Rosati

California Court Rejects Alleged Joint Employers' "It Wasn't Me" Defense to Worker Misclassification Claims

Notwithstanding—and perhaps because of—the emergence of the so-called "sharing economy" and its proliferation of disruptive new business models, as well as calls to re-examine the traditional and familiar employee versus...more

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