Jackpot Harvesting Co. v. Superior Court, 26 Cal. App. 5th 125 (2018)
Labor Code Section 226.2, which became effective Jan. 1, 2016, addresses the manner in which piece-rate employees are to be compensated for rest and recovery periods and other non-productive time on the job (“rest/NP time”). The Court of Appeal held that an employer complying with the statute’s “safe harbor” provision by paying its employees previously unpaid rest/NP time accrued between July 1, 2012 and December 31, 2015 has an affirmative defense against any employee claims for rest/NP time accruing prior to December 31, 2015 (including claims accruing prior to July 1, 2012).