Noori v. Countrywide Payroll & HR Solutions, Inc., 2019 WL 7183403 (Cal. Ct. App. 2019)

Mohammed Noori sued his former employer for violation of Cal. Lab. Code § 226(a) (setting forth certain very specific statutory requirements for itemized wage statements) based on the fact that the wage statements identified “CSSG” as the “name of the legal entity that is the employer” even though CSSG is not listed with the California Secretary of State, but is a fictitious business name for Countrywide Payroll & HR Solutions, Inc. Noori also alleged that Countrywide failed to provide payroll records to him that indicated the employer’s name and address. Finally, Noori alleged violations of the Private Attorneys General Act (“PAGA”). The trial court sustained Countrywide’s demurrer to the complaint and dismissed the lawsuit, but the Court of Appeal reversed in part, holding “CSSG is not Countrywide’s registered name, nor is it a minor truncation. CSSG is a construct… which may or may not have meaning to Countrywide employees.” As for the “failure to maintain wage statement records” claim, the Court held the claim failed for lack of any alleged injury to Noori. Finally, the Court held that Noori had provided adequate notice to the employer under PAGA.