P. ex rel. Garcia-Brower v. Kolla's, Inc.

Summary

The court held that an employee makes a protected disclosure under Labor Code section 1102.5(b) by reporting or complaining about a suspected legal violation to an employer or agency, even when the recipient already knows about the violation. It relied on the statutory text, the Labor Code’s employee-protective purpose, and legislative history showing that the Legislature intended to protect internal reports and complaints. The court concluded that A.C.R.’s wage complaint was protected and remanded for further proceedings. It disapproved contrary precedent to the extent inconsistent with this holding.