Savea v. YRC Inc., 2019 WL 1552686 (Cal. Ct. App. 2019)

Vaiula Savea sued his employer (YRC) for an alleged violation of Labor Code § 226 based upon YRC’s alleged failure to include the correct employer name and address on its wage statements. The alleged violations arose from YRC’s listing on the wage statements its fictitious business name (“YRC Freight” instead of “YRC Inc.”) as the employer name and its inclusion of an employer address that did not contain a reference to the applicable mail stop code or the ZIP+4 Code. The employer successfully demurred to the complaint on the ground that Savea’s complaint failed to state a claim because the employer name and address on its wage statements were in fact accurate. The Court of Appeal affirmed dismissal of the complaint, holding that YRC’s use of its “actual, recorded fictitious business name” (of which the trial court properly took judicial notice) on the wage statements was proper and that the address listed on the wage statements did not need to include the mail stop code or the ZIP+4 Code. See also Myers v. Raley’s, 32 Cal. App. 5th 1239 (2019) (trial court’s denial of employees’ motion for class certification is reversed and remanded for trial court to expand upon its “cursory finding” and issue a statement of reasons for its ruling in order to ensure the court did not employ improper criteria or rely upon erroneous legal assumptions).