Table of Authorities

How to read this

Each entry says where its characterization came from, and the four sources are not equivalent. Some were read against the opinion and recorded in this site’s verification ledger. Some are quoted from analysis already published here. One was drafted while this page was built and has not been reviewed. And fourteen of the 48 decisions carry no holding at all — their citations are confirmed and nothing further has been checked. Four of those are relied on by two or more pages, which is the gap this table exists to make visible rather than to hide.

What the authorities do to each otherEvery edge here was recorded while reading an opinion, and none of it is derivable from a citation. The left column is the decision that acted; the right is what it acted on. seven of the authorities on the right have been disapproved outright. Those are drawn struck through, because a disapproved decision is not a quieter version of a good one — it is no longer law. They are still cited on this site, in their proper posture, which is exactly why a table of authorities has to say so. A solid arrow disapproves; a dashed one distinguishes, which is a materially different thing and the distinction Estrada draws between Wesson and Slesinger in the same opinion. Relationship types are drawn with stroke rather than color, so the figure survives greyscale printing and color stays free to mean what it means everywhere else on this site.Relationships taken from docs/verification-ledger.md, which recorded each one against the opinion. Hohenshelt disapproved eleven Court of Appeal decisions; three of them are drawn here, the three this site cites by name. Estrada disapproved Wesson and expressly distinguished Slesinger rather than disapproving it. Stone disapproved Sargent as to nondefault penalties and called Gateway’s test questionable. ZB disapproved Thurman on another point. Sciborski quotes Koehl at 1335 and cites Steinhebel at 705 — the passage most often attributed to Sciborski is Koehl’s. Sargon quotes Joiner at 146. Duran describes Bell at 724, and everything this site records about Bell is that description.

What the authorities do to each other — underlying values
Acting decision	Relationship	Authority acted on
Hohenshelt	disapproves	Gallo
Hohenshelt	disapproves	Espinoza
Hohenshelt	disapproves	De Leon
Estrada	disapproves	Wesson
Turrieta	disapproves	Moniz
Stone	disapproves	Sargent
ZB, N.A.	disapproves	Thurman
Estrada	distinguishes	Slesinger
Stone	distinguishes	Gateway
Sciborski	quotes	Koehl
Sciborski	quotes	Steinhebel
Sargon	quotes	Joiner
Duran	quotes	Bell v. Farmers

What this site leans on, against what it has readEach bar is the number of pages on this site that name the decision, excluding its own analysis. The fill says how the characterization on the Table of Authorities was arrived at. Read down the bars and the figure is a reliance ranking. Read across the fills and it is a work list: of the 18 most-relied-on decisions drawn here, one carries no holding that anyone has checked against the opinion, and it is marked. A table of authorities that cannot say which of its own entries are unverified is a list of citations wearing the costume of a verification record.Counts computed at build by lib/corpus.js across the publications, dated commentary, industry analyses, case analyses and practitioner guides. A page counts once however many times it names the decision, and a decision is never counted in its own analysis. Matching is on the reporter citation or the full party name, never on a bare surname — "Bell" appears sixteen times on this site and almost every one of them is "Pacific Bell Directory". The count measures reliance by this practice and nothing else: it is not a measure of a decision’s importance, and it is not comparable to any figure outside this corpus. Verification tiers come from the provenance field on data/authorities.js.

What this site leans on, against what it has read — underlying values
Decision	Pages relying on it	How the holding was arrived at
Ferra (2021) 11 Cal.5th 858	13	Characterized in published work
Alvarado (2018) 4 Cal.5th 542	11	Drafted this pass, unreviewed
Donohue (2021) 11 Cal.5th 58	8	Characterized in published work
Estrada (2024) 15 Cal.5th 582	8	Read against the opinion
Naranjo II (2024) 15 Cal.5th 1056	8	Characterized in published work
Brinker (2012) 53 Cal.4th 1004	7	Characterized in published work
Duran (2014) 59 Cal.4th 1	7	Read against the opinion
Naranjo I (2022) 13 Cal.5th 93	7	Characterized in published work
Sciborski (2012) 205 Cal.App.4th 1152	5	Read against the opinion
Adolph (2023) 14 Cal.5th 1104	4	Characterized in published work
Dynamex (2018) 4 Cal.5th 903	4	Characterized in published work
Hohenshelt (2025) 18 Cal.5th 310	4	Read against the opinion
Leeper (2024) 107 Cal.App.5th 1001	4	Characterized in published work
Moniz (2021) 72 Cal.App.5th 56	4	Read against the opinion
Stone (2024) 16 Cal.5th 1040	4	Read against the opinion
Kirby (2012) 53 Cal.4th 1244	3	Characterized in published work
Martinez (2010) 49 Cal.4th 35	3	Characterized in published work
Sargent (2021) 61 Cal.App.5th 658	3	Citation confirmed only

Which provision does what to whichThe first two columns are the audit a demand letter usually skips, and § 2699(f) makes them complements by its own terms: the $100 default is established for every provision of the code “except those for which a civil penalty is specifically provided.” So every row should be marked in exactly one of the two — and the two rows that are not are the ones worth knowing. § 226.7 is marked in both because the first mark is contested: § 558 reaches a section of its own chapter, § 226.7 sits in another, and whether § 558’s wage-order clause carries it is unsettled. § 226 is marked only in the default column even though § 226(e) supplies a penalty, because § 2699(f)(2)(A)(i) names § 226(a)’s paragraphs by number. The third column is why this is a matrix at all. Read as prose, § 2699(i)’s anti-stacking rule is three sentences that sound alike; read as a column it is plainly three different rules. The §§ 201–203 derivative penalty is barred outright — no showing rescues it. § 204 escapes only on willful or intentional conduct. § 226 escapes on knowing or intentional conduct or on a failure to provide a wage statement, which is a disjunctive branch turning on no scienter at all and the half most often dropped. A blank cell means the provision has no bearing on that row, not that it scores nothing.Lab. Code §§ 558, 2699(f)(2), 2699(i), 226.7, 512, 510, 1194, 1197.1, 210, 226, 201–203, 204 and 2802, read from the operative text vendored in data/statutes.generated.js. The last column follows Kirby v. Immoos (2012) 53 Cal.4th 1244 and Naranjo (2022) 13 Cal.5th 93 for § 226.7 premiums and ZB, N.A. (2019) 8 Cal.5th 175 for the underpaid-wages components of §§ 558 and 1197.1. The § 558 boundary at § 226.7 is drawn as contested because this site’s Recoverability Checker states it that way: § 558’s wage-order clause is where the boundary is genuinely disputed and no published decision settles it. § 226.7 is also marked because it is the one cited provision whose operative text this site does not vendor — leginfo serves it as more than one operative version and the fetch records that rather than guessing. No published decision construes § 2699(i)’s wage-statement branch; the reading drawn here is the one the Naranjo Cascade publication states, and it is flagged there as unsettled rather than asserted.

Which provision does what to which — underlying values
Underlying violation	Column	Reading
Meal and rest premiums · § 226.7	Specific civil penalty	§ 558’s first clause reaches “a section of this chapter” — Part 2, Chapter 1 — and § 226.7 sits in Part 1. Whether its second clause, reaching any IWC order provision regulating hours and days of work, carries § 226.7 is genuinely contested and no published decision settles it.
Meal and rest premiums · § 226.7	§ 2699(f)(2) default	With no specific civil penalty settled for § 226.7, the § 2699(f)(2) default governs.
Meal and rest premiums · § 226.7	Wage, not a penalty	The premium is one hour of pay and is a wage, not a penalty — Kirby v. Immoos (2012) 53 Cal.4th 1244; Naranjo (2022) 13 Cal.5th 93. It cannot be collected as a PAGA penalty.
Meal periods · § 512	Specific civil penalty	§ 558(a) supplies $50 for an initial violation and $100 for each subsequent one. § 512 is in the chapter § 558 reaches, so the § 2699(f)(2) default is displaced.
Overtime · § 510	Specific civil penalty	§ 558(a) supplies $50 then $100. A demand running the $100 default on an overtime claim has skipped the first step of the ZB audit.
Overtime · § 510	Wage, not a penalty	§ 1194(a) gives the employee a civil action for “the legal minimum wage or the legal overtime compensation.” The unpaid overtime is a wage; ZB removed § 558’s underpaid-wages component from PAGA.
Minimum wage · § 1194, § 1197.1	Specific civil penalty	§ 1197.1(a) supplies $100 for an initial violation that is intentionally committed and $250 for each subsequent violation for the same specific offense, regardless of intent.
Minimum wage · § 1194, § 1197.1	Wage, not a penalty	§ 1197.1(a) makes restitution of wages and § 1194.2 liquidated damages recoverable in addition to the civil penalty; § 1197.1(a)(3) directs them to the affected employee.
Wage statements · § 226	§ 2699(f)(2) default	§ 2699(f)(2)(A)(i) names paragraphs (1) to (7) and (9) of § 226(a) by number, so the default governs the PAGA penalty even though § 226(e) supplies the employee’s own $50/$100 remedy.
Wage statements · § 226	§ 2699(i) stacking	§ 226 escapes the bar on knowing or intentional conduct, or on a failure to provide a wage statement — a disjunctive branch turning on no scienter.
Final pay · §§ 201–203	§ 2699(f)(2) default	§ 203 continues the employee’s wages as a penalty rather than establishing a civil penalty, so §§ 201–203 violations run on the § 2699(f)(2) default.
Final pay · §§ 201–203	§ 2699(i) stacking	§ 2699(i) bars the stacked §§ 201–203 derivative penalty unconditionally.
Final pay · §§ 201–203	Wage, not a penalty	The unpaid final wages themselves. § 2699(i) bars the stacked penalty, not the employee’s direct claim.
Timely pay · § 204	Specific civil penalty	§ 210(a) reaches a failure to pay wages as provided in § 204: $100 initially, $200 plus 25 percent of the amount unlawfully withheld for a subsequent, willful or intentional violation. § 210(b) makes it a civil penalty when the Labor Commissioner recovers it.
Timely pay · § 204	§ 2699(i) stacking	§ 204 escapes the bar only on willful or intentional conduct — and § 210(a)(2) charges the higher rate on that same showing.
Expense reimbursement · § 2802	§ 2699(f)(2) default	No specific civil penalty is provided for § 2802, so the § 2699(f)(2) default applies.
Expense reimbursement · § 2802	Wage, not a penalty	The unreimbursed expenditure is an amount owed rather than a penalty, and § 2802(b) carries interest from the date it was incurred. § 2802(d) directs recovery to the employee.
Meal and rest premiums · § 226.7	Operative text	Not vendored on this site. leginfo serves more than one operative version and the fetch script records the redirect rather than guessing.

What the corpus rests onEvery page on this site lists its own collection and nothing else, so nothing shows that the mediation guide and the settlement publication stand on the same decisions. This does. The left column is the nine decisions relied on by at least four pages; the right is the fourteen pages that rely on two or more of them. An edge only ever runs between the columns, because a page does not connect to a page — it connects through an authority, and drawing page-to-page lines would invent a relationship nothing in the data supports.Computed at build by lib/corpus.js from the publications, dated commentary, industry analyses, case analyses and practitioner guides. A decision is never counted in its own analysis. Deliberately not the whole graph: the full corpus is 97 authorities against roughly sixty pages, which draws as a hairball that would look impressive and be unreadable. The thresholds are stated rather than tuned to taste — an authority needs 4 relying pages and a page needs 2 drawn authorities. Everything under those thresholds is absent from the drawing and present in the Table of Authorities above, where each entry lists every page relying on it.

What the corpus rests on — underlying values
Decision	Pages relying on it	Holding checked
Ferra (2021) 11 Cal.5th 858	13	Yes
Alvarado (2018) 4 Cal.5th 542	11	Yes
Donohue (2021) 11 Cal.5th 58	8	Yes
Estrada (2024) 15 Cal.5th 582	8	Yes
Naranjo II (2024) 15 Cal.5th 1056	8	Yes
Brinker (2012) 53 Cal.4th 1004	7	Yes
Duran (2014) 59 Cal.4th 1	7	Yes
Naranjo I (2022) 13 Cal.5th 93	7	Yes
Sciborski (2012) 205 Cal.App.4th 1152	5	Yes

Cases48

California and federal decisions cited across this site.

Ferra v. Loews Hollywood Hotel, LLC (2021) 11 Cal.5th 858Published characterization

Cal. Supreme Court · 2021-07-15

“Regular rate of compensation” in § 226.7(c) is synonymous with the “regular rate of pay” used for overtime under § 510(a): it encompasses all nondiscretionary payments for work performed.

What it does not hold

§ 226.7(f)(1)'s security-services carve-out pays its premium at the “regular base hourly rate of compensation” — the base rate, not the rate Ferra construes. That carve-out sunsets January 1, 2027.

Full analysis →

Relied on by 13 pages

PublicationThe Regular Rate Problem: Why Every Commission Plan in California Is a Ticking Clock
CommentaryMartinez v. Sierra Lifestar: Certification Denials Don't Survive a Formulaic Pay Error
IndustryAutomotive (Dealerships)
Case analysisAlvarado v. Dart Container Corp. of California
ResourceCure Proposal Framework
ResourcePenalty Cap Qualification Tracker
ResourceDerivative Cascade Reference
ResourceThree-Scenario Exposure Template
ResourceExpert Deposition Framework
ResourcePre-PAGA Compliance Audit
ResourceRegular Rate Audit Worksheet
ResourceWage Statement Compliance Matrix
ResourceCommission Plan Audit Checklist

Alvarado v. Dart Container Corp. of California (2018) 4 Cal.5th 542Drafted from the opinion

Cal. Supreme Court · 2018-03-05

The per-hour value of a flat-sum bonus for regular-rate purposes is the bonus divided by the nonovertime hours actually worked — not by total hours, which is the federal method.

What it does not hold

It does not decide whether the regular rate is properly calculated on a pay-period or a workweek basis. The court inserted footnote 2 by modification order on April 25, 2018 saying so in terms: the opinion “follows the lead of the parties in using the pay period”, but “we did not grant review to decide” the question and “nothing in this opinion should be interpreted as deciding that question.” This site's regular-rate tools model a workweek and therefore assert nothing the footnote reserves.
29 C.F.R. § 778.109's federal method is not applicable to California — Alvarado declined to follow it.

PostureModified April 25, 2018 (S232607M), inserting footnote 2 and renumbering footnotes 2 through 12.

Full analysis →Opinion →

Relied on by 11 pages

PublicationThe Regular Rate Problem: Why Every Commission Plan in California Is a Ticking Clock
CommentaryMartinez v. Sierra Lifestar: Certification Denials Don't Survive a Formulaic Pay Error
IndustryAutomotive (Dealerships)
Case analysisFerra v. Loews Hollywood Hotel, LLC
ResourceCure Proposal Framework
ResourcePenalty Cap Qualification Tracker
ResourceThree-Scenario Exposure Template
ResourceExpert Deposition Framework
ResourcePre-PAGA Compliance Audit
ResourceRegular Rate Audit Worksheet
ResourceCommission Plan Audit Checklist

Donohue v. AMN Services, LLC (2021) 11 Cal.5th 58Published characterization

Cal. Supreme Court · 2021-02-25

Employers cannot round time punches in the meal period context, and a short or missed meal punch raises a rebuttable presumption of non-compliance.

What it does not hold

Meal-period specific. General time-clock rounding was expressly left open, and is the question pending in Camp v. Home Depot (S277518).

How this was checked →Full analysis →

Relied on by 8 pages

PublicationDrafting PAGA Settlement Approval Motions After Moniz: A Practitioner's Framework
IndustryHospitality
Case analysisBrinker Restaurant Corp. v. Superior Court
ResourceCure Proposal Framework
ResourceDerivative Cascade Reference
ResourceManageability Motion Framework
ResourceExpert Deposition Framework
ResourcePre-PAGA Compliance Audit

Estrada v. Royalty Carpet Mills, Inc. (2024) 15 Cal.5th 582Verified against the opinion

Cal. Supreme Court · 2024-01-18

Trial courts lack inherent authority to strike a PAGA claim on manageability grounds based on judicial economy — the Chief Justice's own section heading.

What it does not hold

Not a due process holding. The court expressly reserved: “we express no opinion as to the hypothetical questions of whether, and under what circumstances, a defendant's right to due process might ever support striking a PAGA claim.” The due process limits on extrapolated proof are Duran's.
It preserves what a defense guide exists to do: the holding “does not preclude trial courts from limiting the types of evidence a plaintiff may present or using other tools to assure that a PAGA claim can be effectively tried.”
Allison v. Dignity Health (2025) 112 Cal.App.5th 192 is an Estrada application, not a construction of § 2699(p).

How this was checked →Full analysis →

Relied on by 8 pages

PublicationStatistical Sampling in Wage-and-Hour Defense: Building a Duran-Compliant Framework
PublicationChallenging Plaintiff's Expert: A Deposition Framework for Statistical Sampling
PublicationManageability After Estrada: Using § 2699(p) to Limit PAGA Scope
IndustryHealthcare & Staffing
IndustryAgriculture
Case analysisDuran v. U.S. Bank National Assn.
ResourceManageability Motion Framework
ResourceExpert Deposition Framework

Naranjo v. Spectrum Security Services, Inc. (2024) 15 Cal.5th 1056Published characterization

Cal. Supreme Court · 2024-05-06

A good-faith belief in compliance defeats the § 226(e) “knowing and intentional” scienter element.

What it does not hold

Distinct from Naranjo (2022) 13 Cal.5th 93, the wages decision.

CitationNaranjo II's official citation was wrong in one citation index for months. Read the opinion header, never the index.

Relied on by 8 pages

PublicationThe Naranjo Cascade: How One Meal Period Violation Generates Four Independent Penalty Streams
Case analysisFerra v. Loews Hollywood Hotel, LLC
Case analysisKirby v. Immoos Fire Protection, Inc.
Case analysisNaranjo v. Spectrum Security Services, Inc.
ResourceCure Proposal Framework
ResourceDerivative Cascade Reference
ResourceRegular Rate Audit Worksheet
ResourceWage Statement Compliance Matrix

Brinker Restaurant Corp. v. Superior Court (2012) 53 Cal.4th 1004Published characterization

Cal. Supreme Court · 2012-04-12

An employer satisfies its meal period obligation by relieving the employee of all duty, relinquishing control, permitting a reasonable opportunity to take an uninterrupted 30-minute break, and not impeding or discouraging it — it need not police that the break is taken.

What it does not hold

It does not require an employer to police that a provided break is actually taken — the obligation is to relieve, relinquish control and not impede.

Full analysis →

Relied on by 7 pages

PublicationDrafting PAGA Settlement Approval Motions After Moniz: A Practitioner's Framework
IndustryHospitality
ResourceCure Proposal Framework
ResourceDerivative Cascade Reference
ResourceManageability Motion Framework
ResourceExpert Deposition Framework
ResourcePre-PAGA Compliance Audit

Duran v. U.S. Bank National Assn. (2014) 59 Cal.4th 1Verified against the opinion

Cal. Supreme Court · 2014-05-29

A trial plan using statistical sampling to establish classwide liability must comport with due process: the sample must be developed with expert input, be genuinely random and representative, and produce a manageable margin of error, and the defendant must be permitted to impeach the model.

What it does not hold

Duran contains zero references to Sargon — confirmed against a control query, so the null is real rather than an indexing artifact. Neither does the other's work.
Whether the 20 names picked for the representative witness group included or excluded the two named plaintiffs is not cleanly resolvable from the opinion, so no subtraction between “picked 20” and “21 testified” is asserted.

How this was checked →Full analysis →

Relied on by 7 pages

PublicationStatistical Sampling in Wage-and-Hour Defense: Building a Duran-Compliant Framework
PublicationChallenging Plaintiff's Expert: A Deposition Framework for Statistical Sampling
CommentaryMartinez v. Sierra Lifestar: Certification Denials Don't Survive a Formulaic Pay Error
Case analysisAdolph v. Uber Technologies, Inc.
Case analysisEstrada v. Royalty Carpet Mills, Inc.
ResourceManageability Motion Framework
ResourceExpert Deposition Framework

Naranjo v. Spectrum Security Services, Inc. (2022) 13 Cal.5th 93Published characterization

Cal. Supreme Court · 2022-05-23

Meal and rest period premium pay under § 226.7 constitutes wages, and is therefore subject to the same reporting and timing rules as any other compensation.

What it does not hold

Distinct from the 2024 Naranjo good-faith decision, (2024) 15 Cal.5th 1056, which construes § 226(e)'s scienter element.

Full analysis →

Relied on by 7 pages

PublicationThe Naranjo Cascade: How One Meal Period Violation Generates Four Independent Penalty Streams
Case analysisFerra v. Loews Hollywood Hotel, LLC
Case analysisKirby v. Immoos Fire Protection, Inc.
ResourceCure Proposal Framework
ResourceDerivative Cascade Reference
ResourceRegular Rate Audit Worksheet
ResourceWage Statement Compliance Matrix

Sciborski v. Pacific Bell Directory (2012) 205 Cal.App.4th 1152Verified against the opinion

Cal. Ct. App., 4th Dist. · 2012-05-08

A commission is not earned until the express contractual conditions are met, so § 221 does not bar recouping an advance if they are not satisfied; once satisfied, the commission is a wage and cannot be recouped.

What it does not hold

The “legal conditions precedent” passage is Sciborski QUOTING Koehl v. Verio, Inc. (2006) 142 Cal.App.4th 1329, 1335, not its own formulation; the advance-recoupment rule cites Steinhebel (2005) 126 Cal.App.4th 696, 705.
Sciborski contains zero references to Schachter. The two leading authorities on when compensation is earned do not cross-reference.

How this was checked →

Relied on by 5 pages

PublicationCommission Forfeiture After Sciborski: The Liability Theory Nobody's Raising
CommentaryThe Commission Forfeiture Theory Nobody's Raising — and Why Every Dealership Should Be Worried
IndustryAutomotive (Dealerships)
ResourceRegular Rate Audit Worksheet
ResourceCommission Plan Audit Checklist

Adolph v. Uber Technologies, Inc. (2023) 14 Cal.5th 1104Published characterization

Cal. Supreme Court · 2023-07-17

An employee whose individual PAGA claim is compelled to arbitration retains standing to litigate the non-individual claims in court.

What it does not hold

Review was limited to standing; the opinion decides nothing else.

How this was checked →Full analysis →

Relied on by 4 pages

PublicationHeadless PAGA and the Leeper Question: A Defense-Side Analysis of the Appellate Split
ResourceEarly Evaluation Conference Playbook
ResourceManageability Motion Framework
ResourceArbitration Agreement Checklist

Dynamex Operations West, Inc. v. Superior Court (2018) 4 Cal.5th 903Published characterization

Cal. Supreme Court · 2018-04-30

Adopts the ABC test for independent contractor classification.

Relied on by 4 pages

Hohenshelt v. Superior Court (2025) 18 Cal.5th 310Verified against the opinion

Cal. Supreme Court · 2025-08-11

Code of Civil Procedure § 1281.98 is not preempted by the FAA, but late payment forfeits the right to arbitrate only where the nonpayment was willful, grossly negligent, or fraudulent.

What it does not hold

The dissent's footnote 2 says § 1281.97 “makes no allowance for parties to agree otherwise” as to an EXTENSION of the due date. Both sections defer identically to an agreed payment window; only § 1281.98(a)(2) adds the agreed-extension clause. Two site surfaces described the distinction the other way and were corrected.
Neither section's material-breach framing distinguishes them — both use it, in identical words.

How this was checked →Full analysis →

Relied on by 4 pages

Leeper v. Shipt, Inc. (2024) 107 Cal.App.5th 1001Published characterization

Cal. Ct. App., 2d Dist. · 2024-12-30

Every PAGA action necessarily includes both an individual and a representative claim, because § 2699(a) authorizes an action “on behalf of the employee and other current or former employees” and “and” is conjunctive.

What it does not hold

Leeper construed the amended § 2699(a); Galarsa's footnote 2 presumes the Supreme Court will analyze the former version, given the March 2024 filing date.

PostureReview granted 2025-04-16 on the court's own motion, S289305. Rodriguez (S290182), Williams (S291199) and CRST Expedited (S292005) are granted-and-held. Balderas v. Fresh Start Harvesting (2024) 101 Cal.App.5th 533 alone remains citable published authority on the split.

How this was checked →Full analysis →

Relied on by 4 pages

Moniz v. Adecco USA, Inc. (2021) 72 Cal.App.5th 56Verified against the opinion

Cal. Ct. App., 1st Dist. · 2021-11-30

Sets out the standard for approving a PAGA settlement, including the requirement that the proposed settlement be submitted to the agency at the same time it is submitted to the court.

What it does not hold

Disapproved by Turrieta “insofar as its analysis and conclusion conflict with ours.”
Its subdivision citations are pre-reform and stale: it cites former § 2699(l)(2) for settlement approval (now § 2699(s)(2)) and recites distribution as 75/25 under former § 2699(i) (now § 2699(m), and 65/35).
Taduran distinguished it as an allocation-among-classes case.

PostureDisapproved in part by Turrieta (2024). The published remand (A168481/A168872, Feb. 28, 2025) dismissed both appeals and declined to widen the personal-interest reservation.

CitationYear discrepancy: the Turrieta slip prints “(2022)”; the filing date is 2021-11-30 and the deciding court's own later opinion prints “(2021)”, which is what this site uses. Flagged for the attorney's confirmation.

How this was checked →

Relied on by 4 pages

PublicationDrafting PAGA Settlement Approval Motions After Moniz: A Practitioner's Framework
IndustryAgriculture
Case analysisTurrieta v. Lyft, Inc.
ResourceMediation Preparation Guide

Stone v. Alameda Health System (2024) 16 Cal.5th 1040Verified against the opinion

Cal. Supreme Court · 2024-08-15

Public entities are not subject to §§ 226.7, 512 or 1174, § 220(b) exempts §§ 200–211 and 215–219 as to employees directly employed by the entity, and public entity employers are not subject to PAGA civil penalties of either kind.

What it does not hold

§ 1198.5 is not in this case — the records claim was §§ 1174, 1174.5 and 1175.
There is no Iskanian-line discussion; Iskanian appears once, for background, and what was disapproved is Sargent.
Gov. Code § 818 was expressly not decided, so there is no sovereign-immunity holding.
Also expressly reserved: the § 226 wage statement ruling, and all pleaded statutes outside the § 220(b) ranges.

CitationThe official citation was verified from three later published opinions, including the Supreme Court's own In re Ja.O., not from the slip header. CourtListener's cluster citations array is empty and must not be relied on.

How this was checked →Full analysis →

Relied on by 4 pages

PublicationRecoverable vs. Non-Recoverable Penalties Under PAGA: What the Statute Actually Authorizes
PublicationHeadless PAGA and the Leeper Question: A Defense-Side Analysis of the Appellate Split
IndustryHealthcare & Staffing
Case analysisZB, N.A. v. Superior Court

Kirby v. Immoos Fire Protection, Inc. (2012) 53 Cal.4th 1244Published characterization

Cal. Supreme Court · 2012-04-30

Neither § 1194 nor § 218.5 authorizes an attorney fee award to any party who prevails on a § 226.7 meal or rest period claim.

Full analysis →

Relied on by 3 pages

Martinez v. Combs (2010) 49 Cal.4th 35Published characterization

Cal. Supreme Court · 2010-05-20

Defines the employment relationship for wage-order purposes.

Relied on by 3 pages

CommentaryMartinez v. Sierra Lifestar: Certification Denials Don't Survive a Formulaic Pay Error
IndustryHealthcare & Staffing
IndustryAgriculture

Sargent v. Board of Trustees of Cal. State University (2021) 61 Cal.App.5th 658Citation confirmed only

Cal. Ct. App., 1st Dist. · 2021-03-09

No holding is stated here. The citation is confirmed; the decision has not been read against its opinion for this site.

PostureDisapproved as to nondefault penalties by Stone v. Alameda Health System.

Relied on by 3 pages

PublicationRecoverable vs. Non-Recoverable Penalties Under PAGA: What the Statute Actually Authorizes
Case analysisStone v. Alameda Health System
Case analysisZB, N.A. v. Superior Court

Augustus v. ABM Security Services, Inc. (2016) 2 Cal.5th 257Verified against the opinion

Cal. Supreme Court · 2016-12-22

On-call rest periods are not rest periods: an employer must relieve employees of all duties and relinquish control during rest breaks.

What it does not hold

Abrogated for the security services industry only, by § 226.7(f)(5), “to the extent that decision is in conflict with this subdivision.” That carve-out sunsets January 1, 2027, at which point Augustus governs that industry again.

PostureAbrogated in part by statute for security services until January 1, 2027 (§ 226.7(f), (g)).

How this was checked →

Relied on by 2 pages

IndustryHospitality
Case analysisBrinker Restaurant Corp. v. Superior Court

Bell v. Farmers Insurance Exchange (2004) 115 Cal.App.4th 715Verified against the opinion

Cal. Ct. App., 1st Dist. · 2004-03-09

The one published California case describing the successful use of statistical sampling at trial in a wage and hour class action, and the affirmative model against which Duran measured the plan before it.

What it does not hold

Everything this site records about Bell is Duran describing Bell at page 724, rather than a reading of Bell itself.

How this was checked →

Relied on by 2 pages

PublicationStatistical Sampling in Wage-and-Hour Defense: Building a Duran-Compliant Framework
Case analysisDuran v. U.S. Bank National Assn.

Iloff v. LaPaille (2025) 18 Cal.5th 551Verified against the opinion

Cal. Supreme Court · 2025-08-21

The § 1194.2(b) good faith defense requires proof the employer “made a reasonable attempt to determine the requirements of the law governing minimum wages”; ignorance of the law is insufficient, and the question is the judge's rather than the jury's.

What it does not hold

Expressly undecided: the extent of inquiry generally required, and whether theft or nonperformance allegations could reduce an award.
The second issue is the paid sick leave law, not § 203 waiting time.
The opinion decides nothing about who counts as an employer; the Dynamex-based employee finding went unchallenged.

PostureThe published remand (A163504, Dec. 23, 2025) holds § 558.1 supports a private right of action and that the statute's “may” marks the employee's election rather than a judicial discretion to excuse the officer.

CitationNo Cal.5th citation appears in the opinion. The reporter cite was closed from four later published opinions, three with pincites.

How this was checked →Full analysis →

Relied on by 2 pages

Case analysisNaranjo v. Spectrum Security Services, Inc.
ResourceCure Proposal Framework

Iskanian v. CLS Transportation Los Angeles, LLC (2014) 59 Cal.4th 348Published characterization

Cal. Supreme Court · 2014-06-23

Pre-dispute PAGA representative claim waivers are unenforceable.

Relied on by 2 pages

Case analysisAdolph v. Uber Technologies, Inc.
ResourceArbitration Agreement Checklist

Kullar v. Foot Locker Retail, Inc. (2008) 168 Cal.App.4th 116Published characterization

Cal. Ct. App., 1st Dist. · 2008-11-18

A court approving a class or PAGA settlement must be presented with a record adequate to an independent assessment of the settlement's value.

CitationA second appeal exists at (2011) 191 Cal.App.4th 1201; the site cites the 2008 decision, which is the correct one for the valuation-record holding.

Relied on by 2 pages

PublicationDrafting PAGA Settlement Approval Motions After Moniz: A Practitioner's Framework
ResourceMediation Preparation Guide

Morales v. 22nd Dist. Agricultural Assn. (2018) 25 Cal.App.5th 85Published characterization

Cal. Ct. App., 4th Dist. · 2018-07-25

Joint-employer status does not transfer an exemption.

Relied on by 2 pages

IndustryHealthcare & Staffing
Case analysisStone v. Alameda Health System

Morillion v. Royal Packing Co. (2000) 22 Cal.4th 575Citation confirmed only

Cal. Supreme Court · 2000-03-27

No holding is stated here. The citation is confirmed; the decision has not been read against its opinion for this site.

Relied on by 2 pages

IndustryHealthcare & Staffing
IndustrySolar & Energy

Pineda v. Bank of America, N.A. (2010) 50 Cal.4th 1389Verified against the opinion

Cal. Supreme Court · 2010-11-18

§ 203 penalties carry a three-year limitations period whether or not unpaid wages are also sought, and are not recoverable as UCL restitution.

How this was checked →

Relied on by 2 pages

ResourceDerivative Cascade Reference
ResourceCommission Plan Audit Checklist

Troester v. Starbucks Corp. (2018) 5 Cal.5th 829Citation confirmed only

Cal. Supreme Court · 2018-07-26

No holding is stated here. The citation is confirmed; the decision has not been read against its opinion for this site.

Relied on by 2 pages

IndustryHospitality
Case analysisDonohue v. AMN Services, LLC

Turrieta v. Lyft, Inc. (2024) 16 Cal.5th 664Verified against the opinion

Cal. Supreme Court · 2024-08-01

A PAGA plaintiff's status as the state's proxy confers no right to intervene in, move to vacate the judgment in, or require a court to receive objections to another employee's overlapping PAGA action.

What it does not hold

The “reverse auction” question was recited and expressly left unresolved, not decided.
The court never reached preclusion of an approved settlement on parallel actions, and no settlement dollar figure appears in the opinion.
Six matters were expressly reserved: operation of the 2024 amendments; whether a PAGA plaintiff has a § 387 personal interest; whether the catalogued procedural problems alone defeat a qualifying intervenor; whether the STATE may intervene, vacate or object; Uribe's correctness; and the state's right to object.
§ 2699(q) preserves consolidation of overlapping PAGA actions, which is the route that survives Turrieta.

CitationThe official citation was verified from two later published opinions that pincite it (Moniz on remand at 710; Soto at 687), not from the slip opinion, which carries none, and not from CourtListener, whose citations array is empty.

How this was checked →Full analysis →

Relied on by 2 pages

PublicationDrafting PAGA Settlement Approval Motions After Moniz: A Practitioner's Framework
Case analysisAdolph v. Uber Technologies, Inc.

Viking River Cruises, Inc. v. Moriana (2022) 596 U.S. 639Published characterization

U.S. Supreme Court · 2022-06-15

The FAA preempts a state rule barring arbitration of an individual PAGA claim.

Relied on by 2 pages

Case analysisAdolph v. Uber Technologies, Inc.
ResourceArbitration Agreement Checklist

Wesson v. Staples the Office Superstore, LLC (2021) 68 Cal.App.5th 746Citation confirmed only

Cal. Ct. App., 2d Dist. · 2021-09-09

No holding is stated here. The citation is confirmed; the decision has not been read against its opinion for this site.

PostureDisapproved by Estrada v. Royalty Carpet Mills (2024) 15 Cal.5th 582.

Relied on by 2 pages

PublicationManageability After Estrada: Using § 2699(p) to Limit PAGA Scope
Case analysisEstrada v. Royalty Carpet Mills, Inc.

ZB, N.A. v. Superior Court (2019) 8 Cal.5th 175Published characterization

Cal. Supreme Court · 2019-09-12

The “amount sufficient to recover underpaid wages” in § 558 is not a civil penalty recoverable through PAGA; only § 558's fixed $50/$100 component can be pursued.

Full analysis →

Relied on by 2 pages

PublicationRecoverable vs. Non-Recoverable Penalties Under PAGA: What the Statute Actually Authorizes
ResourceCure Proposal Framework

Amaral v. Cintas Corp. No. 2 (2008) 163 Cal.App.4th 1157Verified against the opinion

Cal. Ct. App., 1st Dist. · 2008-06-11

Construing the initial-versus-subsequent escalator in former sections 210 and 225.5, the court adopted the notice-based reading: an employer is not on notice that conduct is a violation until it has been told so.

What it does not hold

Amaral construed sections 210 and 225.5, not section 2699(f)(2). It is a reference point for the distinction rather than a construction of the PAGA rate.

How this was checked →

Relied on by 1 page

PublicationThe "Two Hotels" Framework: Temporal Bifurcation in PAGA Penalty Analysis

Armendariz v. Foundation Health Psychcare Services, Inc. (2000) 24 Cal.4th 83Published characterization

Cal. Supreme Court · 2000-08-24

Sets the minimum requirements for an enforceable employment arbitration agreement.

Relied on by 1 page

ResourceArbitration Agreement Checklist

Camp v. Home Depot U.S.A., Inc. (2022) 84 Cal.App.5th 638Citation confirmed only

Cal. Ct. App., 6th Dist. · 2022-10-24

No holding is stated here. The citation is confirmed; the decision has not been read against its opinion for this site.

PosturePending, S277518. Fully briefed since late 2023; on the court's April 2026 pending-issues list; still awaiting argument. Only opinion of record is (2022) 84 Cal.App.5th 638. The question is general time-clock rounding, which Donohue expressly left open.

How this was checked →

Relied on by 1 page

Case analysisDonohue v. AMN Services, LLC

Gallo v. Wood Ranch USA, Inc. (2022) 81 Cal.App.5th 621Citation confirmed only

Cal. Ct. App., 2d Dist. · 2022-07-19

No holding is stated here. The citation is confirmed; the decision has not been read against its opinion for this site.

PostureDisapproved by Hohenshelt v. Superior Court (2025) 18 Cal.5th 310, one of eleven Court of Appeal decisions in the pre-Hohenshelt arbitration-fee line.

How this was checked →

Relied on by 1 page

Case analysisHohenshelt v. Superior Court

Gateway Community Charters v. Spiess (2017) 9 Cal.App.5th 499Citation confirmed only

Cal. Ct. App., 3d Dist. · 2017-03-07

No holding is stated here. The citation is confirmed; the decision has not been read against its opinion for this site.

PostureIts taxing and eminent-domain test was called questionable and distinguished in Stone.

Relied on by 1 page

Case analysisStone v. Alameda Health System

Gattuso v. Harte-Hanks Shoppers, Inc. (2007) 42 Cal.4th 554Citation confirmed only

Cal. Supreme Court · 2007-11-26

No holding is stated here. The citation is confirmed; the decision has not been read against its opinion for this site.

Relied on by 1 page

IndustrySolar & Energy

Koehl v. Verio, Inc. (2006) 142 Cal.App.4th 1329Verified against the opinion

Cal. Ct. App., 1st Dist. · 2006-09-08

A commission is earned when the employee has perfected the right to payment — when all of the legal conditions precedent have been met, those conditions being a matter of contract subject to common law and statutory limits.

What it does not hold

The passage is often attributed to Sciborski, which quotes it at 1335 rather than formulating it.

How this was checked →

Relied on by 1 page

PublicationCommission Forfeiture After Sciborski: The Liability Theory Nobody's Raising

Sargon Enterprises, Inc. v. University of Southern California (2012) 55 Cal.4th 747Verified against the opinion

Cal. Supreme Court · 2012-11-26

Trial courts have a substantial gatekeeping responsibility under Evidence Code sections 801(b) and 802 to exclude expert opinion that is speculative, rests on matter an expert may not reasonably rely on, or is unsupported by the material relied on.

What it does not hold

A lost-profits case, not wage and hour. It states the general California gatekeeping standard and nothing specific to this practice area.
The gatekeeping role “does not involve choosing between competing expert opinions”, does not permit the court to weigh probative value or substitute its own opinion, and does not resolve scientific controversies.
Sargon and Duran do not cross-reference — confirmed against a control query, so the null is real.

How this was checked →

Relied on by 1 page

PublicationChallenging Plaintiff's Expert: A Deposition Framework for Statistical Sampling

Schachter v. Citigroup, Inc. (2009) 47 Cal.4th 610Verified against the opinion

Cal. Supreme Court · 2009-11-02

A forfeiture provision in a voluntary incentive plan does not run afoul of the Labor Code, because no earned, unpaid wages remain outstanding on termination according to the terms of the plan.

What it does not hold

The sentence that payment “may be contingent upon the happening of a future event, such as continued employment” is the Supreme Court reciting and affirming the Court of Appeal, not its own holding sentence.
Schachter and Sciborski do not cross-reference. The two leading authorities on when compensation is earned each stand alone.

How this was checked →

Relied on by 1 page

PublicationCommission Forfeiture After Sciborski: The Liability Theory Nobody's Raising

Stephen Slesinger, Inc. v. Walt Disney Co. (2007) 155 Cal.App.4th 736Citation confirmed only

Cal. Ct. App., 2d Dist. · 2007-09-25

No holding is stated here. The citation is confirmed; the decision has not been read against its opinion for this site.

PostureDistinguished, not disapproved, by Estrada.

Relied on by 1 page

Case analysisEstrada v. Royalty Carpet Mills, Inc.

Steinhebel v. Los Angeles Times Communications (2005) 126 Cal.App.4th 696Citation confirmed only

Cal. Ct. App., 2d Dist. · 2005-02-01

No holding is stated here. The citation is confirmed; the decision has not been read against its opinion for this site.

Relied on by 1 page

PublicationCommission Forfeiture After Sciborski: The Liability Theory Nobody's Raising

Thurman v. Bayshore Transit Management, Inc. (2012) 203 Cal.App.4th 1112Citation confirmed only

Cal. Ct. App., 4th Dist. · 2012-02-14

No holding is stated here. The citation is confirmed; the decision has not been read against its opinion for this site.

PostureDisapproved on another point by ZB, N.A. v. Superior Court.

Relied on by 1 page

Case analysisZB, N.A. v. Superior Court

S.G. Borello & Sons, Inc. v. Dept. of Industrial Relations (1989) 48 Cal.3d 341Published characterization

Cal. Supreme Court · 1989-03-23

Supplies the multifactor test for employment status where an exemption from the ABC test applies.

De Leon v. Juanita's Foods (2022) 85 Cal.App.5th 740Citation confirmed only

Cal. Ct. App., 2d Dist. · 2022-11-23

No holding is stated here. The citation is confirmed; the decision has not been read against its opinion for this site.

PostureDisapproved by Hohenshelt v. Superior Court (2025) 18 Cal.5th 310, one of eleven Court of Appeal decisions in the pre-Hohenshelt arbitration-fee line.

How this was checked →

Espinoza v. Superior Court (2022) 83 Cal.App.5th 761Citation confirmed only

Cal. Ct. App., 2d Dist. · 2022-10-05

No holding is stated here. The citation is confirmed; the decision has not been read against its opinion for this site.

PostureDisapproved by Hohenshelt v. Superior Court (2025) 18 Cal.5th 310, one of eleven Court of Appeal decisions in the pre-Hohenshelt arbitration-fee line.

How this was checked →

Faragher v. City of Boca Raton (1998) 524 U.S. 775Published characterization

U.S. Supreme Court · 1998-06-26

Supplies the affirmative defense to vicarious liability for supervisor harassment.

General Electric Co. v. Joiner (1997) 522 U.S. 136Citation confirmed only

U.S. Supreme Court · 1997-12-15

No holding is stated here. The citation is confirmed; the decision has not been read against its opinion for this site.

Statutes87

Operative text for most of these is vendored and diffed against leginfo at build.

Lab. Code § 2699Text vendored from leginfo

No characterization is stated here. The operative text is vendored from leginfo and diffed at every build — read it at the source link rather than taking a summary for it.

Cases48

Statutes87

Regulations4

IWC Wage Orders6

Session law2

Agency material1