California Supreme Court Watch

#23-94 Stone v. Alameda Health System, S279137. (A164021; 88 Cal.App.5th 84; Alameda County Superior Court; RG21092734.) Petition for review after the Court of Appeal affirmed in part and reversed in part an order in a civil action. This case presents the following issues: (1) Are all public entities exempt from the obligations in the Labor Code regarding meal and rest breaks, overtime, and payroll records, or only those public entities that satisfy the “hallmarks of sovereignty” standard adopted by the Court of Appeal in this case? (2) Does the exemption from the prompt payment statutes in Labor Code section 220, subdivision (b), for “employees directly employed by any county, incorporated city, or town or other municipal corporation” include all public entities that exercise governmental functions? (3) Do the civil penalties available under the Private Attorneys General Act of 2004, codified at Labor Code section 2698 et seq., apply to public entities?

Petition for review granted: 5/17/2023

Case fully briefed: 11/06/2023

See the Court of Appeal Opinion.