Mostly Safe for Work and Work-Related Blog

On 12/19/24, the Equal Employment Opportunity Commission (EEOC) issued a new fact sheet entitled "Wearables in the Workplace; using Wearable Technologies under Federal Employment Discrimination Laws"  The EEOC noted that workplace use of wearables which collect bodily movements, biometric information, and location/GPS tracking, to the extent the "wearables" collect health data they can be considered to be conditioning "medical examinations' or making disability-related inquiries under the American with Disabilities Act, and therefore must be "job-related and consistent with business necessity."  The EEOC also cautioned about using collected information in employment decisions, which could violate Title VII of the Civil Rights Act of 1964 (Title VII).  The EEOC also reminded employers that exceptions or reasonable accommodations might become necessary under Title VII, the ADA, or the Pregnant Workers' Fairness Act (PWFA): https://www.eeoc.gov/w...

On 12/27/24, in Leeper v. Shipt, Inc ., the California Court of Appeals held that an independent contractor's individual PAGA claims must be arbitrated despite her contention that she did not allege individual PAGA claims, since she would not have standing for her representative claims unless she also alleged individual claims. The Court also held that the plaintiff's representative PAGA claims should be stayed while her non-representative (individual) PAGA claims were arbitrated, though the duration of the stay was subject to the Court's discretion: https://www4.courts.ca.gov/opinions/documents/B339670.PDF

 On 12/11/24, the Los Angeles City Council voted to approve a draft ordinance proposal to increase the minimum wage for the tourism industry ahead of the 2028 Los Angeles Olympics, and instructed the Los Angeles City attorney to draft an ordinance to increase wages to a minimum of $30 per hour by July 2028: https://www.latimes.com/business/story/2024-12-11/la-city-council-votes-on-30-hour-minimum-wage-for-hotel-airport-workers https://abc7.com/post/la-city-council-approves-hourly-minimum-wage-hike-tourism-workers/15643568/

According to Court documents filed in a civil lawsuit related to a criminal case filed against Dr. Kevin Tien Do, USA v. Do , Do named an Orange County Superior Court judge, Israel Claustro, as the true owner of Liberty Medical Group, Inc. Prosecutors allege that Do submitted fraudulent medical reports through Liberty Medical Group after his 2018 suspension from the workers' compensation system, while using other doctor names to conceal his involve net. Allegedly $1.5 million of fraudulent proceeds went to Liberty Medical Group's owners (including Claustro) while Do personally received over $300,000: https://www.dailyjournal.com/articles/382644-judge-named-in-relation-to-workers-comp-scheme https://www.latimes.com/california/story/2024-12-24/o-c-judge-tied-to-healthcare-fraud-scheme-with-convicted-doctor https://www.ocregister.com/2024/12/13/oc-judge-allegedly-conspired-with-doctor-who-defrauded-state-workers-comp-program/  

On 12/30/24, in Markel v. Union of Orthodox Jewish Congregations of America,  the Ninth Circuit Court of Appeals held that the First Amendment's Ministerial Exception barred a mashgiach (minister, or key employee) from bringing employment-related claims against his employer, where the employer was a non for profit corporation serving the kosher certification program for the Orthodox Jewish community in the United States.  The Court held that the employee's employment-related claims were barred, as the Ministerial Exception precludes the application of "laws governing the employment relationship between a religious institution and certain key employees": https://cdn.ca9.uscourts.gov/datastore/opinions/2024/12/30/23-55088.pdf

On 12/27/24, in NLRB v. Starbucks Corp ., the Third Circuit held that the National Labor Relations Board (NLRB) did not have the power to award consequential damages (interim employment costs and work search costs) to workers as a result of alleged labor law violations by Starbucks, where the alleged violations were not directly related to lost wages or benefits.  In doing so, the Third Circuit limited a controversial 2022 NLRB decision, Thryv, Inc. , in which the NLRB ruled that employers were on the hook for "all direct or foreseeable" damages arising from a violation of the National Labor Relations Act (NLRA), including out of pocket medical expenses, or even missed mortgage or rent payments: www2.ca3.uscourts.gov/opinarch/231953p.pdf

On 12/27/24, the California Court of Appeals issued a decision in Huff v. Interior Specialists, Inc. , reversing the trial court's dismissal of an employee's non-individual PAGA claims, and directing the trial court to stay those claims, pending completion of the arbitration of the employees' individual claims. Since the Court reversed the trial court on this ground, the Court did not address the employee's additional argument that the trial court erred in finding that she signed an arbitration agreement (where another employee's name was prefilled when she was given the arbitration agreement): https://www4.courts.ca.gov/opinions/documents/D082036.PDF

On 12/23/24, the California Court of Appeals issued a decision in C ounty of Los Angeles Sheriff's Department v. Los Angeles County Civil Service Commission , and affirmed the denial of a petition for a writ of administrative mandamus sough by the Department. The Court of Appeals rejected the Department's argument that a 30-day suspension was inadequate in light of the officer's dishonesty regarding an investigation, and noted that the "Department has a policy of progressive disciple, and the 30-day suspension fell within the range recommended....": https://www4.courts.ca.gov/opinions/nonpub/B327545.PDF

On 12/27/24, the Division of Workers Compensation ("DWC") issued a press release to alert employers and health care professional to be on the lookout for occupational cases of bird flu, after noting that bird flu had allegedly been identified among dairy farmworkers and poultry farmworkers in other states. The DWC encouraged employees to have bird flu and apply for workers' compensation benefits: https://www.dir.ca.gov/DIRNews/2024/2024-114.html

On 12/23/24, in a move evoking the COVID crisis that arose during Trump's first term, California Governor Gavin Newsom proclaimed a State of Emergency to streamline and expedite the state's response to Bird Flu, while the Labor & Workforce Development Agency (LWDA) and California Department of Public Health (CDPH) engaged in an outreach strategy to educate workers about the Bird Flu, though the CDPH admits that the current risk is low and there is no known person-person spread in California: www.gov.ca.gov/wp-content/uploads/2024/12/CORRECT-ATTESTED.pdf https://www.dir.ca.gov/dosh/avian-flu/For-Employers.html https://www.dir.ca.gov/dosh/avian-flu/ https://www.cdph.ca.gov/Programs/CID/DCDC/Pages/Bird-Flu.aspx

On 12/3/24, the California Court of Appeals issued its opinion in Gonzalez v. Nowhere Beverly Hills, LLC , and held that an employee who signed an arbitration agreement and later filed a wage and hour class action lawsuit, cannot avoid arbitration by suing and arguing that related entities are "joint employers" (the plaintiff's employer's parent and sister companies) while still arguing that arbitration does not apply because the related parties were not signatories to the arbitration agreement: https://www4.courts.ca.gov/opinions/documents/B328959.PDF

On 11/19/24, the California Labor Workforce Development Agency (LWDA) issued updates to its frequently asked questions regarding Private Attorneys' General Act (PAGA) claims processing in light of recent legislative reports (California enacted AB 2288 and SB 92 which took effect on June 19, 2024, and instituted needed reforms to PAGA): https://www.labor.ca.gov/resources/paga/paga-faqs/ https://www.dir.ca.gov/Private-Attorneys-General-Act/Private-Attorneys-General-Act.html https://www.labor.ca.gov/resources/paga/

On 12/23/24, the California Division of Workers' Compensation (DWC) issued adjustments to the official medical fee schedule for physician and non-physician practitioner services section of the Official Medical Fee Schedule (OMFS) to conform to the 2025 changes in the Medicare payment system, as required by Labor Code § 5307.1: https://www.dir.ca.gov/DIRNews/2024/2024-113.htm l https://www.dir.ca.gov/dwc/OMFS9904.htm#7

On 12/20/24, the California Court of Appeals issued its opinion in Ramirez v. Moreno Valley Unified School District , finding that a calendaring slip-up excused the failure of the Dominguez Firm to file a claim against a public entity within the six (6) month filing claim filing period under Government Code  § 911.2, but that neglect by the lawyer assigned to the case to keep an eye on the file and discover the error justified denial of relief to the plaintiff by the trial court judge, Nicholas Firetag of Riverside County Superior Court: https://www4.courts.ca.gov/opinions/nonpub/D083775.PDF  

On 12/20/24, the Los Angeles County Superior Court awarded $3.9 million in attorneys' fees to Shegerian & Associates in attorneys' fees in the case of Pinter-Brown v. UC Regen ts.  However, the defense attorneys have filed a notice of appeal. The plaintiff, Dr. Pinter-Brown had previously been awarded $14 million by a jury verdict in May 2024. This followed a similarly large jury verdict at trial in 2018, which was reversed and remanded by the California Court of Appeals. https://www.dailyjournal.com/article/382595-shegerian-awarded-3-9m-in-fees-against-uc-regents#:~:text=Shegerian%20awarded%20%243.9M%20in,says%2C%20but%20Regents%20will%20appeal

On 12/20/24, the California Division of Workers' Compensation (DWC) announced the increase of the mileage rate for Medical and Med-Legal Travel Expenses from $.67/mile to $.70/mile, effective January 1, 2025, under Labor Code § 4600.  This followed the IRS's announcement of the same amount of rate increase for standard mileage reimbursement rates for business use in 2025: https://www.dir.ca.gov/DIRNews/2024/2024-112.html https://www.irs.gov/newsroom/irs-increases-the-standard-mileage-rate-for-business-use-in-2025-key-rate-increases-3-cents-to-70-cents-per-mile https://www.dir.ca.gov/dwc/I&A_mileageForm.pdf

 On 12/19/24, the California Occupational Safety and Health (Cal/OSHA) Standards Board voted to make 12/29/23 emergency regulations permanent for the protection of workers from respirable crystalline silica (especially those working with artificial man-made stone): https://www.dir.ca.gov/DIRNews/2024/2024-111.html https://www.dir.ca.gov/oshsb/documents/Respirable-Crystalline-Silica-Non-Emergency-txtbrdconsider.pdf https://www.dir.ca.gov/title8/5204.html https://www.dir.ca.gov/DIRNews/2023/2023-93.html

On 12/19/24, the California Division of Workers' Compensation posted an order adjusting the Durable Medical Equipment, Prosthetics, Orthotics and Supplies Section to the OMFS to conform to Medicare's 2025 Payment System Changes: https://www.dir.ca.gov/DIRNews/2024/2024-110.html https://www.dir.ca.gov/dwc/OMFS9904.htm#3

On 12/19/24, the California Division of Workers' Compensation announced the revision of the Official Medical Fee Schedule that provides the maximum reasonable fees for pharmaceuticals for injured workers after 7/1/25, which were updated to conform to Medi-Cal methodology changes and Labor Code provisions setting forth additional rules for doctor dispensed drugs, and adopting Med-Cal's two (2) tier dispensing fee for pharmacies with higher fees for pharmacies listed on the Medi-Cal National Provider Identifier (NPI): https://www.dir.ca.gov/DIRNews/2024/2024-108.html

On 12/2/24, the Labor Commissioner issued a new Frequently Asked Questions (FAQ) website listing, which includes changes taking place on 1/1/25, including changes resulting from amendments relating to time off for victims of acts of violence, clarifying the difference between accrual, carryover, and use, and clarifying the difference between employees who are fully versus partially exempt from sick leave requirements: https://www.dir.ca.gov/dlse/Paid_Sick_Leave.htm 

On 12/11/2024, the Fifth Circuit Court of Appeals issued a decision in Alliance for Fair Board Recruitment v. SEC , overturned a panel decision, and invalidated NASDAQ's Board Diversity Rule, which had previously been approved by the SEC, which required companies on the NASDAQ to provide a demographic breakdown of the board of directors, and required a standard to have one (1) self-identified female director, 1 director who self-identified as a minority or as LGBTQ or provide a brief explanation why the standard had not been met: https://www.ca5.uscourts.gov/opinions/pub/21/21-60626-CV0.pdf 

On 11/20/24, the California Court of Appeals issued a decision in J enkins v. Dermatology Mgmt., LLC , in which it held that an arbitration agreement was procedurally and substantively unconscionable where the employer representative signed the agreement before the employee was ever provided the agreement (thus a "take it or leave it" condition of employment, and the agreement required the employee but not her employer to arbitrate claims, the agreement shortened the limitations period to one (1) year, the agreement imposed unreasonable restrictions on discovery, and the agreement required the parties to equally share the arbitrator's fees and costs: https://www4.courts.ca.gov/opinions/documents/B333759.PDF

 On 12/19/24, thousands of Amazon.com workers and Teamsters' members went on strike during the last days before the end of the 2024 Christmas shopping season, with picket lines anticipated at hundreds of fulfillment centers nationwide: https://www.wsj.com/business/retail/amazon-workers-strike-union-61af8da6   https://www.wsj.com/business/retail/amazon-teamsters-vote-to-authorize-strikes-at-two-new-york-warehouses-union-says-0a47a247?mod=article_inline

 On 11/26/24, in Torres v. Prudential Financial, In c. a California federal district court issued an opinion granting class certification to a wiretapping claim brought against Prudential for using third party technology to track users activity in violation of the California Invasion of Privacy Act: https://casetext.com/case/torres-v-prudential-fin

In 12/2024, OSHA began issuing Injury Tracking Application (ITA) data (safety case details) from OSHA 300 and 301 forms.  OSHA now publishes OSHA Form 300SA Summary Data by establishment as well as available Form 300 and Form 301 data :  https://www.osha.gov/Establishment-Specific-Injury-and-Illness-Data

 On 12/16/21, the US Department of Labor withdrew its 2021 "80/20/30" rule on tip credits, which required employers to pay tipped workers the full minimum wage for all time spent providing "directly supporting work" (i.e., side work like cleaning and setting tables if it exceeds 20% of their hours in the workweek, and when tupped workers performed such work for more than 30 minutes, even if more than 20% of their hours worked).  The DOL's withdrawal occurred following the 5th Circuit's issuance of a ruling in Restaurant Law Center v. DOL which found no basis for the rule in the FLSA and held that the rule was arbitration and capricious.  https://public-inspection.federalregister.gov/2024-29798.pdf https://www.ca5.uscourts.gov/opinions/pub/23/23-50562-CV0.pdf

On 12/18/24, the U.S. Equal Employment Opportunity Commission (EEOC) issued information for healthcare providers to help their patients obtain pregnancy and childbirth-related accommodations under the Pregnant Workers Fairness Act (PWFA). The PWFA is a new law that requires employers to reasonably accommodate employees' conditions related to pregnancy, childbirth, or related medical conditions:   https://www.eeoc.gov/newsroom/eeoc-releases-pwfa-information-health-care-providers https://www.eeoc.gov/laws/guidance/helping-patients-deal-pregnancy-and-childbirth-related-limitations-and-restrictions https://www.eeoc.gov/statutes/pregnant-workers-fairness-act

On 12/17/24, President Biden designated Gwynne A. Wilcox as Chair of the National Labor Relations Board (NLRB).  Wilcox is the first black female chair of the NLRB, previously served on the NLRB from 2021 to 2023, and was confirmed by the Senate on 9/6/23 for a second term ending in 2028: https://www.nlrb.gov/news-outreach/news-story/president-biden-designates-gwynne-a-wilcox-as-chair-of-the-national-labor

 On 12/10/24, the U.S. National Labor Relations Board (NLRB) issued a decision in Endurance Environmental Solutions, LLC , in which it reinstated a prior NLRB standard and overruled MV Transportation, Inc. , 368 NLRB 66 (2019), and disallowed the "contract coverage" test in which employers could argue unilateral changes to working conditions were permissible if within the scope of contract language or whether the issue was discussed during the parties bargaining history, and finding that there must be a "clear and unmistakable waiver" of an issue by a union: https://www.nlrb.gov/news-outreach/news-story/board-returns-to-clear-and-unmistakable-waiver-standard https://apps.nlrb.gov/link/document.aspx/09031d4583eb2156

 On 12/17/24, the California Labor Commissioner's office issued a notice reminding employers that California's minimum wage increases to $16.50 per hour on January 1, 2025 for employers regardless of size:   https://www.dir.ca.gov/DIRNews/2024/2024-107.html https://www.dir.ca.gov/dlse/faq_minimumwage.htm

On 12/16/24, the US Attorney General's office announced that Dr. Kevin T. Do agree to plead guilty to conspiring to defraud California's Subsequent Injuries Benefits Trust Fund (SIBTF) by writing reports on which he listed other doctors' names, after he was previously suspended from participating in California's workers' compensation program because a 2003 conviction for federal health care fraud: https://www.justice.gov/usao-cdca/pr/pasadena-doctor-agrees-plead-guilty-conspiring-attorney-bilk-more-3-million 

On 12/17/24, the California Supreme Court granted the WCAB's petition for review of the decision in Mayor v. WCAB , which found that the WCAB impermissibly granted reconsideration more than 60 days after the filing of a petition for reconsideration under former Labor Cod e § 5909. In its Petition, the WCAB argued that the 60-day timeline be equitably tolled and should not begin until the WCAB can actually review the petition and the Court of Appeal's decision in Mayor v. WCAB exceeded the discretion available under traditional mandamus procedures: https://supreme.courts.ca.gov/sites/default/files/supremecourt/default/2024-12/pendingissues-civil%20-%20121324_0.pdf

On 12/17/2024, the California Court of Appeals issued its decision in Zavala v. Hyundai Motor America , holding that a defendant's statutory offer to compromise under California Code of Civil Procedure § 998 was still valid, even where it included two different but independent options for Plaintiff to consider, one of which was sufficiently specific and certain and over the amount of the verdict, though the other offer was invalid due to lack of specificity: https://www4.courts.ca.gov/opinions/documents/D082747.PDF

 On 12/17/24, Cal/OSHA cited Harbor Animal Services Center with a $563,250 fine for a willful serious accident-related violation after a worker was mauled, and for failing to evaluate and correct overcrowding at their animal shelter which resulted in animal attacks and bites, and after an employee was mauled on May 31, 2024, due to the employer's willful safety violations: https://www.dir.ca.gov/DIRNews/2024/2024-106.html 

On 12/12/24, the California Division of Occupational Safety & Health (Cal/OSHA) issued its first serious willful health violation to a landscape contractor for willfully violating California's heat illness prevention regulations, after receiving a worker complaint about lack of access to water or heat illness training: https://www.dir.ca.gov/DIRNews/2024/2024-105.html

On 12/11/24, the Court of Appeal reversed a $150 million trial court jury verdict to the family of a worker killed in a power plan exposure and ordered a new trial regarding whether the parent company was liable for the worker's death. The Court of Appeals ruled that a jury instruction on the Privette Doctrine was inappropriately denied by the trial court judge (holding that the hirer of an independent contractor delegates responsibility for workplace safety to the contractor and is not responsible for the contractor's workers' injuries) was appropriate: https://courts.ca.gov/opinion/g062752

 On 12/11/2024, Hazel Ortega, the CEO of California's largest vocational return to work counseling center,  Ortega Counseling Center, appeared in court after being charged on 7/24/24 with 23 felony counts of insurance fraud, theft, and forgery following an investigation by the California Department of Insurance. As a result, the Division of Workers Compensation has added Ortega and several other providers to the Labor Code § 4615 list and noted that her liens have been stayed: https://www.insurance.ca.gov/0400-news/0100-press-releases/2024/release061-2024.cfm https://www.insurance.ca.gov/0400-news/0100-press-releases/2024/release038-2024.cfm https://www.dir.ca.gov/Fraud_Prevention/4615-List.htm

On 12/11/24, Gustavo Cisneros pled no contest to felony insurance fraud, after an investigation by the Sacramento County DA's office found he was exaggerating his claimed injuries and limitations, had used 6 different social security numbers and dates of birth to make his prior claims more difficult to defect, and where he told his private doctors that he had no prior conditions or workers' compensation claims: https://www.sacda.org/2024/12/defendant-sentenced-for-workers-compensation-insurance-fraud   

On 12/13/24, the California Court of Appeals reversed a trial court's decision in Winston v. County of Los Angeles , holding that an award of attorneys' fees applied to the action as the case was pending on the date the Legislature amended Labor Code § 1102.5 to add a provision allowing reasonable attorneys' fees to prevailing plaintiffs: https://www4.courts.ca.gov/opinions/documents/B323392.PDF

 On 12/11/24, the California Court of Appeals denied United Airlines petition for rehearing in Wawarzenski v. United Airlines , but modified the opinion to add a footnote stating that consideration of comparisons with other supervisors was sound where they following the same policies and procedures while the employer coordinates disciplinary actions nationally to ensure consistent standards, and where there was supervisor testimony that he had consulted with management to ensure he was consistently applying company policies before terminating the plaintiff: https://www4.courts.ca.gov/opinions/documents/B327940M.PDF  

On 12/10/24, the Ninth Circuit Court of Appeals issued a panel ruling affirming the district court's granting of summary judgment to Allegiant Air and the Transport Workers Union in an airline worker's action alleging that the CBA between Allegiant and the TWU violated the Railway Labor Act of 1926. The Ninth Circuit held that the RLA does not prohibit a CBA conditioning employment or bidding privileges based on payment of union dues or agency fees, which the plaintiff had not paid: https://cdn.ca9.uscourts.gov/datastore/opinions/2024/12/10/23-16156.pdf  

On 12/10/24, the Ninth Circuit Court of Appeals issued its opinion in  Hansen v. Musk , affirming the district court's dismissal of a complaint alleging whistleblower claims under the Sarbanes Oxley Act (SOX), holding that although SOX claims are not subject to mandatory prelitigation arbitration agreements, a confirmed arbitral award can preclude relitigation of the issues underlying a SOX claim - here, the arbitration award precluded a SOX claim since it conclusively resolved Hansen's other arbitrable claims: https://cdn.ca9.uscourts.gov/datastore/opinions/2024/12/10/23-15296.pdf

On 12/10/24, in Chavez v. California Collision, Inc ., the California Court of Appeals issued a decision in which it reversed the trial court's award of costs to defendants under CCP § 998 as being in violation of Labor Code §§ 1194 and 218.5, noting the different standards under these Labor Code provisions for awarding costs ( Labor Code  § 218.5 requires bad faith by the plaintiff, while Labor Code  § 1194 applies only to minimum wage, overtime, and 17200 claims): https://www4.courts.ca.gov/opinions/documents/A167658.PDF  

The U.S. Department of Labor (DOL) has issued a new proposed rule to end the practice of paying some disabled workers less than the federal minimum wage, which previously allowed subminimum wage payment "when necessary to prevent curtailment of opportunities for employment": https://public-inspection.federalregister.gov/2024-27880.pdf

In  Howell v. State Department of State Hospitals , the California Court of Appeals affirmed a trial court decision reducing the payment of attorneys' fees to a prevailing party in a FEHA disability discrimination action, from $1.7 million claimed by counsel, to $135,102), where the trial court found the time spent was "shocking" and "beyond all reason" and included "block-billed" entries: https://www4.courts.ca.gov/opinions/documents/A168526.PDF

On 12/9/24, the US Supreme Court issued its oral argument transcript in Feliciano v. U.S. Dept. of Transportation , a case dealing with differential pay statutes for civilian reservists: https://www.supremecourt.gov/oral_arguments/argument_transcripts/2024/23-861_6kgm.pdf  

The California Labor Commissioner has issued a new Whistleblower's Notice - "Whistleblowers Are Protected" - for posting by California Employers: https://www.dir.ca.gov/dlse/WhistleblowersNotice.pdf 

The California Division of Workers' Compensation (DWC)  has announced draft regulations for proposed changes to SJDB/RTW rules, which would require itemization for vocational billings, require that education programs be required by public schools or EDD-approved providers or schools, prohibit conflict of interests by Vocational Rehabilitation (Voc Rehab) counselors, create a process for removal of previously approved Voc Rehab counselors, and update the SJDB voucher form and instructions: https://www.dir.ca.gov/DIRNews/2024/2024-99.html

The California Division of Workers' Compensation (DWC) has announced that, beginning on March 1, 2025, all hearings (status conferences, MSCs, priority conferences, and lien conferences) will begin using the Court Call video platform exclusively.  All WCAB judges will have a link to their virtual courtroom available on the DWC's website.  All trials, expedited hearings, and lien trials will continue to be in-person https://www.dir.ca.gov/DIRNews/2024/2024-100.html

In Mendoza v. West Coast Quartz Corp ., the California Court of Appeals upheld the trial court's denial of a motion to disqualify and held that there was no conflict of interest in representing both supervisory and non-supervisory (but all non-exempt) class members/aggrieved employees (under PAGA): http://www.metnews.com/articles/2024/disqualification_120524.htm  

In a recent case,  Trujillo v. J&M Manufacturing Co ., the California Court of Appeals held that Cal. Code Civ. Proc. (CCP) section 1281.98 (requiring the timely payment of arbitration fees in order to avoid waiving arbitration) applies to pre-dispute, not post-dispute arbitration agreements: https://www4.courts.ca.gov/opinions/documents/B327111.PDF

On 12/5/24, in  Howell v. Dept. of State Hospitals , the California Court of Appeals held that a jury verdict awarding no pain and suffering damages was not inadequate, since the employee did not suffer a physical injury, there was no evidence of undisputed evidence of pain, and suffering connected to her determination, and no evidence of jury misconduct. The Court also struck the jury's award of health benefits where there was no evidence that she lost her insurance due to her termination. /www4.courts.ca.gov/opinions/nonpub/A168526.PDF

California's Minimum Wage will increase to $16.50 per hour on January 1, 2025:  https://dof.ca.gov/wp-content/uploads/sites/352/2024/08/Minimum-Wage-Increase_Director-of-Finance_Determination-and-Certification_Website.pdf 

A new article in the Los Angeles Daily Journal describes recent large verdicts in employment cases are driven by young people irritated by corporations following the Pandemic:  https://www.dailyjournal.com/articles/382306-gen-z-jurors-are-driving-big-verdicts-and-defense-lawyers-are-swiping-left