Huerta v. CSI Elec. Contractors, 15 Cal. 5th 908 (2024)

This decision arose from a class action asserting wage claims on behalf of contractors hired to assist with “procurement, installation, construction, and testing services” at a solar power facility on privately-owned land.  The California Supreme Court answered three questions certified by the Ninth Circuit as follows:

• An employee’s time spent on an employer’s premises awaiting and undergoing an employer-mandated exit procedure that includes a visual inspection of the employee’s personal vehicle is compensable as “hours worked”;
• The time an employee spends traveling between a security gate and employee parking lots is compensable as “employer-mandated travel” under Wage Order No. 16 (governing the construction industry), if the security gate was the first location where the employee’s presence was required for an employment-related reason other than the practical necessity of accessing the worksite; and
• When an employee is covered by a collective bargaining agreement that provides the employee with an “unpaid meal period,” that time is nonetheless compensable as “hours worked” if the employer prohibits the employee from leaving the employer’s premises or a designated area during the meal period and if this prohibition prevents the employee from engaging in otherwise feasible personal activities.