Naranjo v. Spectrum Sec. Services, 172 Cal. App. 4th 654 (2009)

Gustavo Naranjo worked as a detention officer for Spectrum, which provides security services in holding facilities and detention centers throughout Los Angeles County under a contract with federal Immigration and Customs Enforcement (“ICE”). The terms of Spectrum’s contract with ICE rely on wage and fringe benefit determinations by the Secretary of the U.S. Department of Labor pursuant to the McNamara-O’Hara Service Contract Act of 1965 (“SCA”). In this putative class action, Naranjo alleged violations of the California Labor Code involving meal and rest period requirements, failure to pay additional compensation upon the resignation or discharge of employees, and failure to provide employees with itemized records of their wages and deductions. Spectrum defended on the ground that Naranjo’s claims were preempted by the SCA. The trial court agreed and granted Spectrum’s motion for summary judgment, but the Court of Appeal reversed, holding that Naranjo’s claims neither conflicted with nor hindered the achievement of the SCA’s goals. Cf. Solis v. Matheson, 563 F.3d 425 (9th Cir. 2009) (overtime provisions of FLSA apply to a business located on an Indian reservation and owned by Indian tribal members); Ahlmeyer v. Nevada Sys. of Higher Educ., 555 F.3d 1051 (9th Cir. 2009) (the ADEA is the exclusive federal remedy for age discrimination in employment).