California Supreme Court
Naranjo v. Spectrum Security Services, Inc.
May 23, 2022
Summary
The court held that premium pay for missed meal or rest breaks is wages because it compensates employees for work performed under unlawful conditions, and therefore it may support waiting-time penalties and wage-statement penalties when the statutory prerequisites are met. The court also held that the default 7 percent constitutional rate, rather than the 10 percent wage-nonpayment rate, applies to prejudgment interest on missed-break premium-pay awards. The court reversed in part and remanded for determination of willfulness and knowing-and-intentional conduct.