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To embed, copy and paste the code into your website or blog: Update February 10, 2021: This blog has been updated to reflect current guidance about California meal and rest break laws. On September 26, 2019, California’s Second District Court of Appeals in Gustavo Naranjo, et al. v. Spectrum Security Services, Inc. held that unpaid premium wages for meal break violations do not entitle employees to additional remedies under the California Labor Code for inaccurate wage statements or waiting time penalties. By limiting employees’ ability to bring derivative inaccurate wage statement and unpaid wage claims, the decision immediately decreases employers’ overall exposure for Labor Code penalties, class counsel’s attorneys’ fees, and civil penalties under the Private Attorneys General Act (PAGA).

United statesGustavo naranjoIndustrial wage commissionDavis wright tremaineCalifornia second district courtSpectrum security services incCalifornia courtCalifornia supreme courtSecond district courtSecurity servicesCalifornia labor codeLabor codePrivate attorneys general actWage commission ordersSpectrum security servicesAppeal decision