In Vranish v. Exxon Mobil Corp., ___ Cal.App.4th ___ (Jan. 22, 2014), the California Court of Appeal (Second Appellate District, Division Two) affirmed the ruling of the Los Angeles County Superior Court (Judge Mooney) granting summary judgment to the defendant employer on plaintiffs’ claims of unpaid overtime.
Plaintiffs – unionized employees whose employment was covered by a collective bargaining agreement between their union and their employer – filed a lawsuit for unpaid overtime wages and related causes of action. The defendant employer then moved for summary judgment based on California Labor Code Section 514, which provides that the state’s overtime provisions “do not apply to an employee covered by a valid collective bargaining agreement if the agreement expressly provides for wages, hours of work, and working conditions of the employees, and if the agreement provides premium wage rates for all overtime hours worked and a regular hourly rate of pay for those employees of not less than 30 percent more than the state minimum wage.” The court agreed and granted the motion. Plaintiff’s appealed, arguing that the phrase “all overtime hours worked” in section 514 means “overtime” as defined by the California Labor Code.
The appellate court disagreed and affirmed the lower court’s ruling. The appellate court determined that “based upon the plain language of section 514, legislative history, an opinion from the Department of Industrial Relations, Division of Labor Standards Enforcement (DLSE), and public policy, . . . [that definition] does not apply to section 514.