Thursday, April 12, 2012

California Supreme Court Reverses Court of Appeal, in Part: Brinker Restaurant Corp. v. Superior Court

The California Supreme Court has finally ruled, issuing a 63 page opinion that addresses questions pertaining to both certification and the construction of California meal/rest break laws.  The Court’s overarching ruling, as set forth in the introduction of the opinion, is as follows:
On the ultimate question of class certification, we review the trial court’s ruling for abuse of discretion. In light of the substantial evidence submitted by plaintiffs of defendants’ uniform policy, we conclude the trial court properly certified a rest break subclass. On the question of meal break subclass certification, we remand to the trial court for reconsideration. With respect to the third contested subclass, covering allegations that employees were required to work “off-the-clock,” no evidence of common policies or means of proof was supplied, and the trial court therefore erred in certifying a subclass. Accordingly, because the Court of Appeal rejected certification of all three subclasses, we will affirm in part, reverse in part, and remand for further proceedings.
See Slip Opinion, at 2. 

I am working on reviewing and unpacking the Court’s analysis, and will have a more detailed review shortly.

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