The case involved a dispute between the Los Angeles Unified School District and the Trustees of the Southern California IBEW-NECA Pension Plan over whether Labor Code section 1776, subdivision (e) created an absolute privilege preventing the District from disclosing unredacted certified payroll records containing employees' names, addresses, and Social Security numbers in response to discovery requests. The Trustees sought the records to identify and allocate unpaid employee fringe benefits owed by a contractor under a Project Stabilization Agreement. After a bench trial, the court ruled in favor of the Trustees, holding that the statute imposes only a conditional privilege under Evidence Code section 1040 rather than an absolute bar. The core reasoning was that the redaction requirement applies specifically to public inspection of records held by awarding agencies, not to discovery in litigation, and that any confidentiality interests must be balanced against the Trustees' demonstrated need for the information to enforce benefit contributions.
The case involved attorneys who represented injured workers before the Workers’ Compensation Appeals Board (WCAB) filing class action lawsuits against employers and insurers for failing to pay interest on attorney fee awards. The trial court sustained a demurrer and dismissed the actions for lack of subject matter jurisdiction. The Court of Appeal affirmed, holding that while the attorneys had standing to seek the interest, the superior court lacked jurisdiction to enforce payment of interest because the WCAB awards did not expressly include it, and the proper forum was the WCAB itself under the exclusive provisions of the Workers’ Compensation Act.
In Morgan v. United Retail Inc., a former employee filed a class action lawsuit alleging that the employer's wage statements violated Labor Code section 226 by listing regular and overtime hours separately without including their sum on a distinct line. The trial court granted summary adjudication to the employer, and the appellate court affirmed, holding that the statements satisfied the statute's requirement to show total hours worked. The court reasoned that separately itemizing regular and overtime hours provided the precise total hours worked by employees, meeting the statutory mandate without need for an additional summed line. The decision focused on statutory compliance rather than any claimed injury or intent.
In Scalzo v. Baker, Frederick Scalzo sued his brother Martin Scalzo along with Martin's attorneys and accountants for obtaining and sharing his private American Express credit card statements without permission, alleging invasion of privacy, violations of the Gramm-Leach-Bliley Act and California Financial Information Privacy Act, and seeking injunctive relief for the return of the records. The trial court granted the attorneys' and accountants' special motions to strike the injunctive relief claim under the anti-SLAPP statute, and the appellate court affirmed that ruling while reversing as to Martin. The court reasoned that the attorneys' and accountants' conduct qualified as protected activity under the anti-SLAPP statute because it occurred in connection with litigation over funds from jointly held property, and the plaintiff did not demonstrate a probability of prevailing against them.
In Mendoza v. Ramos, the parents of four minor children disputed a modification to custody and child support orders after the father sought to reduce his payments by attributing income to the mother, who received CalWORKs public assistance while complying with the program's counseling and educational requirements. The trial court declined to impute earnings to the mother, set the father's income at a stipulated amount, and ordered him to pay $873 monthly in child support. The Court of Appeal affirmed, holding that Family Code section 4058 permits consideration of earning capacity only when consistent with the children's best interests, and that requiring the mother to work or forgo assistance would interfere with her approved program. The court also rejected the father's claim of denied cross-examination rights, finding he forfeited the issue by not requesting live testimony at the hearing.
The case involved a class action lawsuit under California's unfair competition law brought by Andrew Arce, a child with autism, against Kaiser Foundation Health Plan and related entities. Arce alleged that Kaiser violated the Mental Health Parity Act by categorically denying coverage for behavioral therapy and speech therapy to treat autism spectrum disorders, instead treating them as non-covered educational or custodial care. The trial court sustained Kaiser's demurrer without leave to amend, citing judicial abstention and lack of commonality among class members. The Court of Appeal reversed, holding that Arce could potentially establish the community of interest required for a class action and that resolving the claims would not necessitate individualized medical necessity determinations or intrude on matters reserved for administrative agencies.