California Supreme Court Watch

#20-02 Naranjo v. Spectrum Security Services, Inc., S258966. (B256232; 40 Cal.App.5th 444; Los Angeles County Superior Court; BC372146.)  Petition for review after the Court of Appeal affirmed in part and reversed in part the judgment in a civil action. This case presents the following issues: (1) Does a violation of Labor Code section 226.7, which requires payment of premium wages for meal and rest period violations, give rise to claims under Labor Code sections 203 and 226 when the employer does not include the premium wages in the employee’s wage statements but does include the wages earned for meal breaks? (2) What is the applicable prejudgment interest rate for unpaid premium wages owed under Labor Code section 226.7?

Petition for review granted: 1/02/2020

Case fully briefed: 7/10/2020

Cause argued and submitted: 3/01/2022

Opinion filed: Judgment reversed: 5/23/2022

See the California Court of Appeal Order.

See the Petition for Review.

See the Oral Argument.

See the California Supreme Court Opinion.  (Naranjo v. Spectrum Security Services, Inc. (2022) 13 Cal.5th 93.)

“We reverse in part the judgment of the Court of Appeal, insofar as it held the failure to timely pay or report section 226.7 premium pay can never support relief under Labor Code sections 203 and 226, and remand for further proceedings in the Court of Appeal not inconsistent with this opinion.”

Majority Opinion by Kruger, J., joined by Cantil-Sakauye, C. J., Corrigan, Liu, Groban, Jenkins, and O’Leary, JJ.