The First District Court of Appeal held that California plaintiffs may pursue statutory damages under the Fair Credit Reporting Act without proving concrete injury, departing from the Fifth District’s Limon decision and reversing a class decertification order.
California appeals court holds that Humboldt County can be sued for failing to enroll a 40-year court reporter in CalPERS and losing her personnel records, establishing that pension enrollment and record-keeping are mandatory duties enforceable under Government Code section 815.6.
First District holds that a direct employer cannot enforce an arbitration agreement the worker originally signed with a temporary staffing agency, where the worker’s claims arose entirely from the direct-employment period that started after the temp placement ended.
First District holds that an arbitrator’s merits-based finding that an employee did not suffer Labor Code violations preclusively destroys the same employee’s PAGA standing in the companion court action.
First District holds the First Amendment ministerial exception does not categorically bar a Zen Center worker’s wage-and-hour claims, but Labor Code section 98.2’s appeal bond is required only of the employing entity, not individuals also liable under section 558.1.