Troester v. Starbucks Corp., 5 Cal. 5th 829 (2018)

In this opinion, the California Supreme Court answered a legal question from the United States Court of Appeals for the Ninth Circuit:  “Does the federal Fair Labor Standards Act’s de minimis doctrine…apply to claims for unpaid wages under California Labor Code sections 510, 1194 and 1197?”  The California Supreme Court answered the question as follows:  “We hold that the relevant wage order and statutes do not permit application of the de minimis rule on the facts given to us by the Ninth Circuit, where the employer required the employee to work ‘off the clock’ several minutes per shift.”  See also Rangel v. PLS Check Cashers of Cal., Inc., 2018 WL 3892987 (Cal. Ct. App. 2018) (employee’s putative FLSA collective action was barred by a state class action settlement that released all claims on which her FLSA action was predicated).