Labor Law Class Action Against Water Storage District Properly Dismissed by Trial Court because Water District Subject to Federal Labor Laws but not State Labor Laws California State Court Holds
Plaintiff filed a putative class action in California state court against his employer, Arvin-Edison Water Storage District (the District), alleging violations of California’s labor code; the class action complaint alleged that defendant failed to pay its employees overtime or to provide meal breaks required by California law. Johnson v. Arvin-Edison Water Storage District, 174 Cal.App.4th 729, 95 Cal.Rptr.3d 53, 55 (Cal.App. 2009). Defense attorneys demurred to the class action complaint on the grounds that “as a public entity, [defendant] is exempt from the subject wage and hour statutes.” Id. The trial court agreed and dismissed the class action, id. Plaintiff appealed, “argu[ing] that, contrary to the trial court’s ruling, public employers are subject to the California wage and hour provisions at issue unless they are expressly made exempt.” Id. The California Court of Appeal affirmed the dismissal of the class action, finding that the District is a “municipal corporation” and therefore exempt from California labor laws. Id., at 55-56.
Plaintiff argued that “the [California] Legislature intended that water storage districts provide their employees with overtime and meal periods as required by [California law].” Johnson, at 55. The appellate court summarized the formation of the District and its compliance with the federal Fair Labor Standards Act (FLSA), see id., at 56, the Court observed that the facts were undisputed and the questions of law were subject to independent review, id. (citation omitted). And based on the appellate court’s detailed analysis, the Court concluded that the District is a public agency exempt from California’s labor laws. Id., at 57-62. Accordingly, it affirmed the trial court judgment and awarded costs on appeal to the District, id., at 62.