Judge: Armen Tamzarian, Case: 23STCV22536, Date: 2025-01-17 Tentative Ruling

Case Number: 23STCV22536    Hearing Date: January 17, 2025    Dept: 52

Cross-Defendant Peter Alexan Enterprises, Inc.’s Motion for Judgment on the Pleadings

Cross-defendant Peter Alexan Enterprises, Inc., doing business as RA Consulting (RA), moves for judgment on the pleadings on the cross-complaint by Jara Blash. 

PAGA

RA contends Blash did not adequately exhaust her administrative remedies for her claims under the Private Attorneys General Act (PAGA).   Before filing a PAGA action, the plaintiff “must provide notice to the employer and the responsible state agency ‘of the specific provisions of [the Labor Code] alleged to have been violated, including the facts and theories to support the alleged violation.’ ”  (Williams v. Superior Court (2017) 3 Cal.5th 531, 545.)  “[T]he ‘facts and theories’ provided in support of ‘alleged’ violations” are not required to “satisfy a particular threshold of weightiness, beyond the requirements of nonfrivolousness generally applicable to any civil filing.”  (Ibid.) 

The notice requirement distinguishes “between the alleged violation (i.e., ‘the allegations an aggrieved employee is making’) and the facts and theories to support the alleged violation (i.e., ‘any basis for those allegations’).”  (Brown v. Ralphs Grocery Co. (2018) 28 Cal.App.5th 824, 836 (Brown).)  “[A] string of legal conclusions that parrot[s] the allegedly violated Labor Code provisions” is insufficient because it does “not state facts and theories supporting the alleged violations.”  (Id. at p. 837.)  But “few ‘facts and theories’ are needed to satisfy PAGA’s notice requirement.”  (Rojas-Cifuentes v. Superior Court of San Joaquin County (2020) 58 Cal.App.5th 1051, 1057.) 

Blash’s pre-filing notice (Cross-Comp., Ex. A) includes sufficient facts and theories.  The notice states, “The plaintiff worked for Defendant and was misclassified as a salaried exempt employee.  Plaintiff alleges that she and other workers, including purported ‘event managers’ who were working as supposed independent contractors, were misclassified and should have been classified as employees.”  (Id., p. 1.)  The notice provides further allegations of the facts and theories underlying each category of violation.  (Id., pp. 1-4.) 

Two Court of Appeal decisions are instructive.  Brown held a PAGA notice was adequate as to failure to provide complete wage statements where the notice alleged the employer failed “ ‘to include the name and address of the legal entity that is the employer.’ ”  (Brown, supra, 28 Cal.App.5th at p. 838.)  Uribe v. Crown Building Maintenance Co. (2021) 70 Cal.App.5th 986 (Uribe) held a notice alleging defendant failed to reimburse employee expenses “ ‘for purchasing slip resistant shoes and maintaining [plaintiff’s] uniform” was inadequate as to claims for reimbursement for use of personal cell phones.  (Id. at p. 1005.) 

An employer can violate the law on wage statements in numerous ways, such as by omitting any of the nine items specified in Labor Code section 226, subdivision (a), or by simply not providing wage statements at all.  Blash’s notice letter adequately specified the wage statements were not “accurate”, did not “include[] the total hours worked,” did not “show the start and end date for each pay period,” among other specified violations.  (Cross-Comp., Ex. A, pp. 3-4.)  As in Brown, these allegations suffice.    

Similarly, employees can incur a broad variety of expenses subject to reimbursement.  Blash’s notice letter adequately specified the aggrieved employees’ expenses: “the cost of using their personal cell phones for business related purposes.”  (Cross-Comp., Ex. A, p. 3.)  The letter further stated, “Defendant required that Plaintiff be available by cell phone and answer/use their cell phones while working and this was necessary to perform their job duties.”  (Ibid.)  Under Uribe, these allegations suffice as to failure to reimburse the cost of using personal cell phones.

Blash’s other claims are largely self-explanatory and can generally be violated in only one way.  For example, for meal periods, the notice letter alleged, “Defendant failed to apprise Plaintiff and the Aggrieved Employees of their rights associated with meal periods and failed to provide timely meal periods.  Defendant has had a consistent policy of: (1) requiring Plaintiff and the Aggrieved Employees to work during meal breaks that occurred after the first five hours of each shift; (2) required Plaintiff and the Aggrieved Employees to work shifts over ten (10) hours without providing a second meal period of thirty minutes in length altogether; and (3) failed to pay such employees one (1) hour of pay at the employees regular rate of compensation for each workday that the first meal period was not provided within the first (5) hours of the shift or that a second meal period was not provided.”  (Cross-Comp., Ex. A, p. 2.)  Hours worked are hours worked.  Not providing breaks or paying the penalty is an ultimate fact. 

As for claims based on minimum wage or overtime, the only necessary allegations are facts showing RA underpaid Blash.  The notice letter alleged, “These statutes require an employer to compensate its employees at the minimum wage rate for all hours worked and at a rate of no less than one and one-half times the regular rate of pay for any work in excess of eight hours in one workday, double time for any hours beyond 12 hours per day, and any work in excess of 40 hours in any one workweek.  Plaintiff and other aggrieved employees were not paid at the proper corresponding rate for all overtime hours worked, including overtime as a result of Defendant’s failure to pay overtime at the legal rates.”  (Cross-Comp., Ex. A, p. 2.)  The facts and theories underlying this claim, therefore, are that Blash and other aggrieved employees sometimes worked more than 8 hours or 12 hours in a day or more than 40 hours in a week, but RA did not pay increased overtime rates.  Moreover, the notice letter alleges Blash “was misclassified as a salaried exempt employee.”  (Id., p. 1.)  In other words, she was paid a regular salary not calculated based on the number of hours she worked, which necessarily means she did not get increased overtime pay. 

Similarly, Labor Code section 203 imposes penalties on employers who willfully fail to pay wages of an employee after separation of employment.  Blash’s notice letter states she “was not paid all wages due upon [her] separation from Defendant’s employ.”  (Cross-Comp., Ex. A, p. 4.)  That constitutes the necessary ultimate fact.  Nothing else is required.

Unfair Competition

As to Blash’s cause of action for unfair competition (Bus. & Prof. Code, § 17200), RA argues the violations “are based on the legally defective PAGA Notice.”  (Memo, p. 10.)  For the reasons discussed above, the PAGA notice is not legally defective.  Blash thus alleges sufficient facts for her unfair competition claim.

Disposition

Cross-defendant Peter Alexan Enterprises, Inc.’s motion for judgment on the pleadings is denied.