Supreme Court on Groff v. DeJoy: Clarifying Religious Accommodation Requirements for Employers

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Groff v. DeJoy clarified legal requirements employers must meet for employees seeking religious accommodations at work (referencing the Civil Rights Act of 1964, Title VII). Before the U.S. Supreme Court's landmark decision in this case, the "de minimis" standard was accepted. However, the Supreme Court's decision redefined the standard for religious accommodations in the workplace, moving beyond the previous standard and emphasizing that employers must demonstrate that accommodating an employee's religious observance would substantially increase costs relative to their business operations.

Case: Groff v. Dejoy

Court: U.S. Supreme Court

Case No.: 22–174

The Plaintiff: Gerald E. Groff v. Louis DeJoy

Gerald Groff, an evangelical Christian and former postal worker in Pennsylvania sought exemption from Sunday work to observe his Sabbath. Initially, the U.S. Postal Service (USPS) accommodated his request. However, as operational demands increased, Groff was scheduled for Sunday shifts. However, Groff refused to work the assigned Sunday shifts (due to religious reasons), and his refusal to work Sunday shifts led to disciplinary actions that prompted him to resign from his position and file a labor law lawsuit alleging his employer violated Title VII.

The Defendant: Gerald E. Groff v. Louis DeJoy

The USPS was represented by Louis DeJoy, Postmaster General, in the lawsuit. USPS argued that to exempt Groff from Sunday shifts posted an undue hardship that required them to reassign his duties to other workers, and claimed the situation would result in potential disruptions to mail delivery.

The Case: Gerald E. Groff v. Louis DeJoy

The court ruled for Groff - unanimously. The court clarified the "undue hardship" standard under Title VII as requiring employers to show that providing requested accommodations for an employee's religious practices would significantly increase costs relative to overall operations costs. The clarification moved away from the previous interpretation that allowed employers to deny accommodations based on a minimal burden.

Can Employees Obtain Religious Accommodations at Work?

Employees are empowered to seek accommodations for their religious practices, with the assurance that their requests cannot be dismissed based on minimal inconvenience to the employer. Employers must carefully consider requests for religious accommodations and make sure that any accommodations request denial is based on evidence showing fulfilling the request would cause a significant increase in costs or a significant disruption of day-to-day operations.

If you need to discuss filing a wage and hour complaint, contact Blumenthal Nordrehaug Bhowmik DeBlouw LLP. Experienced and knowledgeable employment law attorneys are ready to assist you at one of their various law firm offices in Riverside, San Francisco, Sacramento, San Diego, Los Angeles, and Chicago.

Landmark Viking River Cruises Case: Supreme Court Decision Limits PAGA Claims

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The 2022 Supreme Court ruling in the Viking River Cruises Case significantly altered the legal landscape surrounding California's Private Attorneys General Act (PAGA). In Viking River Cruises v. Moriana, the Court concluded that individual claims under PAGA could be forced into arbitration. Importantly, the Court indicated that when individual claims go to arbitration, representative claims made on behalf of other employees would no longer have standing and must be dismissed.

Case: Viking River Cruises v. Moriana

Court: Supreme Court

Case No.: 20-1573

The Plaintiff: Viking River Cruises v. Moriana

Angie Moriana, a former employee of Viking River Cruises, filed a lawsuit under California's PAGA, alleging that the company violated several provisions of the California Labor Code. Moriana sought to represent herself and other aggrieved employees, bringing both individual and representative claims.

The Defendant: Viking River Cruises v. Moriana

Viking River Cruises contended that Moriana had signed an employment agreement mandating individual arbitration for labor disputes and explicitly waiving rights to bring class or representative actions. The company argued that the Federal Arbitration Act (FAA) required the enforcement of such arbitration agreements, thereby blocking Moriana's representative claims in court.

The Case: Viking River Cruises v. Moriana

The June 2022 Supreme Court decision was a decisive ruling that stated the FAA mandates the enforcement of arbitration agreements even in the context of PAGA claims. According to the decision, employees bound by arbitration agreements must arbitrate their individual claims and, upon arbitration, lose standing to pursue representative claims for other employees in court. However, the California Supreme Court complicated matters in 2023 by clarifying that plaintiffs could still bring representative PAGA claims in state court even if their individual claims proceeded separately through arbitration.

If you need to discuss filing a wage and hour complaint, contact Blumenthal Nordrehaug Bhowmik DeBlouw LLP. Experienced and knowledgeable employment law attorneys are ready to assist you at one of their various law firm offices in Riverside, San Francisco, Sacramento, San Diego, Los Angeles, and Chicago.

California’s Metal Container (MCC) Faces a PAGA-Only Action Claiming Violations

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In a recent PAGA-Only action, Metal Container, a California product packaging service provider, faces allegations of labor code violations.

The Case: John Dedet v. Metal Container (MCC) LP

The Court: Los Angeles County Superior Court

The Case No.: CVRI2405838

The Plaintiff: John Dedet v. Metal Container (MCC) LP

The plaintiff, John Dedet, worked for Metal Container (MCC) from July 2021 through June 2024 as an hourly nonexempt employee. As a nonexempt hourly employee, Dedet was entitled to labor law protections, including minimum wage requirements, overtime pay regulations, mandatory meal breaks and rest periods, and more.

The Defendant: John Dedet v. Metal Container (MCC) LP

The defendant, Metal Container (MCC) LP, is a California company and employer that provides product packaging services throughout the state—according to the plaintiff, Dedet, Metal Container (MCC) LP failed to provide their workers with meal breaks and rest breaks mandated by labor law. Failing to comply with rest period and meal break requirments often leads to additional violations. In this case, the plaintiff claims the standard practice allegedly meant lost wages for workers.

The Allegations: John Dedet v. Metal Container (MCC) LP

Dedet claims that Metal Container engaged in several labor law violations that were connected to their standard operating processes. The PAGA-Only action alleges violations of Labor Code § 2699 and California Labor Code §§ 201-203, 204, 210, 218, 221, 226(a), 226.7, 227.3, 246, 510, 512, 558(a)(1)(2), 1194, 1197, 1197.1, 1198, 2100, and 2802.

What's the Definition of California's PAGA-Only Action?

In California, employees have the right to initiate a lawsuit under the Private Attorneys General Act (PAGA), which serves as a tool for the state to uphold labor laws via employees who act on behalf of the state's labor enforcement agencies. A PAGA-only lawsuit primarily serves as a regulatory measure to safeguard public interests, not for the personal gain of any individual. Instead of pursuing personal damages or restitution, this type of action empowers an employee to act as a private enforcer of the California Labor Code, effectively granting them the role of a private attorney general.

The Case: John Dedet v. Metal Container (MCC) LP

In John Dedet v. Metal Container (MCC) LP, the plaintiff filed a PAGA-Only action currently pending in the Riverside County Superior Court.

If you have questions about filing a California PAGA-Only action, don't hesitate to get in touch with Blumenthal Nordrehaug Bhowmik DeBlouw LLP. Knowledgeable employment law attorneys are ready to assist you in various law firm offices in Riverside, San Francisco, Sacramento, San Diego, Los Angeles, and Chicago.

Did Medical Management International, Inc. Fail to Reimburse Employees for Work Expenses?

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In recent news, a California lawsuit alleges that Medical Management International, Inc. violated labor law when they failed to reimburse employees for necessary work expenses.

The Case: Amber Wolfing v. Medical Management International, Inc.

The Court: Solano County Superior Court of the State of California

The Case No.: 24CV007705

The Plaintiff: Amber Wolfing v. Medical Management International, Inc.

Amber Wolfing, who was engaged as a non-exempt hourly employee by the defendant in August 2019, initiated a class action lawsuit against Medical Management International. She claims that the company's illegal policies and practices resulted in the failure to adequately compensate their employees, as required by labor law.

The Defendant: Amber Wolfing v. Medical Management International, Inc.

Medical Management International, Inc., which offers veterinary healthcare services across California, is the defendant in the case brought by the plaintiff, Amber Wolfing. Wolfing alleges that during her employment, she was compelled to work during her off-duty meal breaks and also before shifts, performing mandatory COVID checks and temperature screenings without pay. Additionally, she contends that the company habitually engaged in "rounding" employees' clock-in and clock-out times in a manner that consistently benefited the employer, consequently leading to underpayment for the actual hours worked by employees.

What is "Time Worked" According to California Labor Law?

Under California labor law, "time worked" is defined as any period during which an employee remains under an employer's control, encompassing all instances where the employee is either actively working or is allowed to work, regardless of necessity. Instances of "time worked" include:

  • Periods when the employee is on duty, present on the employer's premises, or stationed at a designated work location.

  • Times when the employee is allowed to work, even if they are not engaging in their primary job functions.

  • Moments when the employee must remain on the employer's premises or at a specific location controlled by the employer, which limits their ability to engage in personal activities.

This broad definition ensures that employees in California receive compensation for all time spent under employer directives, not limited to just productive work time. It includes time spent waiting, on standby, traveling under certain conditions, and performing other duties as dictated by the job and level of control exercised by the employer. This approach guarantees that workers are paid for all the time their freedom is restricted by job requirements.

The Case: Amber Wolfing v. Medical Management International, Inc.

Amber Wolfing alleges that due to the routine practice of rounding employee work hours at Medical Management International, Inc., she, along with other members of the class action in California, were deprived of their rightful minimum wage, overtime compensation, and legally mandated meal breaks, contrary to both federal and California Labor Laws. She argues that the defendant's failure to compensate employees for all hours worked is demonstrable through the company's own business records. The case, Amber Wolfing v. Medical Management International, Inc., is presently active in the Solano County Superior Court in California.

If you have questions about filing an employment law lawsuit, please contact Blumenthal Nordrehaug Bhowmik DeBlouw LLP. Experienced employment law attorneys are ready to assist you in various law firm offices in San Diego, San Francisco, Sacramento, Los Angeles, Riverside, and Chicago.

LibertyMax Staffing Faces Allegations of Labor Law Violations

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In recent news, California’s LibertyMax Staffing faces labor law violation allegations.

The Case: Brian Acio v. San Gabriel Temporary Staffing Services LLC dba LibertyMax Staffing

The Court: San Joaquin County Superior Court of the State of California

The Case No.: STK-CV-UOE-2024-0001294

The Plaintiff: Acio v. LibertyMax Staffing

The plaintiff in the case, Acio, filed a representative action complaint against San Gabriel Temporary Staffing Services LLC dba LaborMax Staffing ("LaborMax Staffing") for allegedly failing to provide employees with timely, off-duty meal and rest periods. Acio claims the company engaged in a pattern and practice of wage and hour labor code violations to decrease its employment-related costs.

The Defendant: Acio v. LibertyMax Staffing

The defendant in the case, LibertyMax Staffing, owns and operates a recruiting and staffing company that operates throughout California. According to the class action wage and hour lawsuit, the company allegedly violated several labor laws, including:

  • Failing to pay minimum wage and overtime wages

  • Failing to reimburse employees for necessary business expenditures

  • Failing to provide employees with required meal breaks and rest periods

  • Failing to provide workers with accurate itemized wage statements

  • Failing to provide sick pay wages

  • Failing to provide workers with their full wages when they were due

  • Failing to correctly calculate the regular rate of pay

  • Failing to maintain true and accurate records

  • Failing to issue payment within 7 days of the close of payroll

California Employers and Labor Law Violations: Off-the-Clock Work

Off-the-clock work is one of California's most prevalent practices leading to labor law violations. This occurs when employees are asked or expected to perform job-related tasks outside of their regular working hours without receiving compensation. Off-the-clock work may come in the form of answering emails after hours, attending mandatory meetings or training without pay, completing required paperwork after clocking out, conducting “opening” or “closing” procedures and checklists before or after clocking in, etc. Such business practices violate labor laws, as employees are entitled to compensation for all hours worked, including any time spent performing job duties “before” or “after” their work shift.

The Case: Acio v. LibertyMax Staffing

The representative action lawsuit, Acio v. LibertyMax Staffing, is currently pending in the Sacramento County Superior Court of the State of California.

If you have questions about filing an employment law lawsuit, please contact Blumenthal Nordrehaug Bhowmik DeBlouw LLP. Experienced employment law attorneys are ready to assist you in various law firm offices in San Diego, San Francisco, Sacramento, Los Angeles, Riverside, and Chicago.

PAGA-Only Action Filed Against Formel D USA, Inc.

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In recent news, a PAGA-only action was filed against Formel D USA, Inc.

The Case: Oddae Alghazali v. Formel D USA, Inc.

The Court: Orange County Superior Court

The Case No.: 30-2023-01369309-CU-OE-CXC

The Plaintiff: Oddae Alghazali v. Formel D USA, Inc.

The plaintiff in the case, Oddae Alghazali, alleges that Formel D USA, Inc. violated Labor Code § 2699. Alghazali filed a PAGA-only action seeking penalties for the alleged violations of the California Labor Code.

The Defendant: Oddae Alghazali v. Formel D USA, Inc.

The defendant in the case, Formel D USA, Inc., faces a PAGA-only action based on allegations that they failed to provide employees with required meal and rest breaks. And that by doing so, they failed to provide their workers with payment for all hours worked. According to the lawsuit filed by Alghazali, Formel D USA, Inc. failed to provide employees with legally required meal and rest breaks when they (from time to time) required employees to work in more than four (4) hours without being provided a ten (10) minute rest period. According to the California Wage Order, California employers must provide their employees with off-duty rest periods.

The California Supreme Court determined that for a rest period to qualify as an “off-duty rest period,” it must fulfill two requirements: 1. the employee must be relieved of all their job duties, and 2. the employee must be free from the employer’s control.

The Case: Oddae Alghazali v. Formel D USA, Inc.

The case, Oddae Alghazali v. Formel D USA, Inc., is currently pending in the Orange County Superior Court. PAGA-only actions like the one in this case allow the State of California to enforce state labor laws through individual employees who file a lawsuit as the proxy of the state’s labor law enforcement agencies. PAGA-only actions are essentially law enforcement actions intended to protect the public rather than benefit private parties. Therefore, a PAGA-only action does not seek to recover damages or restitution but acts as a means of “deputizing” citizens as private attorneys general so they can step in to help the state enforce the California Labor Code.

If you have questions about filing an employment law lawsuit, please contact Blumenthal Nordrehaug Bhowmik DeBlouw LLP. Experienced employment law attorneys are ready to assist you in various law firm offices in San Diego, San Francisco, Sacramento, Los Angeles, Riverside, and Chicago.

Uber Eats Background Check Violations Lead to $3.35M Class Action Settlement

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In recent news, Uber Eats resolved allegations that their background checks violated labor law with a $3.35 million class action settlement.

The Case: Aguilera et al. v. Uber Technologies Inc. d/b/a Uber Eats

The Court: New York State Supreme Court for Kings County

The Case No.: 509275/2023

The Plaintiff: Aguilera et al. v. Uber Eats

The plaintiff in the case, Aguilera, claimed Uber Eats ran a criminal background check process for prospective drivers in New York City between October 24, 2015, and July 28, 2021, which violated labor law. The settlement class is divided into two groups:

Group 1: Consists of class members with serious convictions more likely to be considered job-related due to the nature of the conviction and the recent date of the conviction.

Group 2: Consists of class members with convictions less likely to be considered job-related.

The Defendant: Aguilera, et al. v. Uber Eats

The defendant in the case, Uber Eats, a prominent player in the food delivery service industry, has faced legal scrutiny in New York due to allegations of denying job opportunities to prospective drivers based on what is claimed to be a flawed background check process. This lawsuit stems from accusations that Uber Eats violated the rights of individuals seeking employment as delivery drivers in New York City.

The Case: Aguilera, et al. v. Uber Eats

The case, Aguilera et al. v. Uber Eats, was resolved with a $3.35 million settlement. Primarily, the settlement benefits prospective drivers who were denied the opportunity to be Uber Eats drivers in New York City based on the results of a criminal background check. The dispute in Aguilera et al. v. Uber Eats centers around the period spanning from October 2015 through July 202, when numerous applicants argued that they were unfairly denied opportunities to work for the Uber Eats platform based on the results of these background checks.

If you have questions about how to file an employment law lawsuit, please get in touch with Blumenthal Nordrehaug Bhowmik DeBlouw LLP. Experienced employment law attorneys are ready to assist you in various law firm offices in San Diego, San Francisco, Sacramento, Los Angeles, Riverside, and Chicago.