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Martinez v. Combs

Supreme Court of California

May 20, 2010, Filed

S121552

Case Summary

Procedural Posture

The California Court of Appeal affirmed a summary judgment for defendants, an employer and two produce merchants through whom the employer sold strawberries, on plaintiff seasonal agricultural workers' claims under Lab. Code, §§ 1194 and 1194.2, and also affirmed a summary judgment for one of the produce merchant on plaintiffs' claim as purported third-party beneficiaries of the merchant's contract with the employer. Plaintiffs sought review.

Overview

Plaintiffs claimed the Industrial Welfare Commission's (IWC) wage order No. 14-2001, entitled "Order Regulating Wages, Hours, and Working Conditions in the Agricultural Occupations," Cal. Code Regs., tit. 8, § 11140, commonly known as Wage Order No. 14, defined the produce merchants as their employers for purposes of § 1194. The court held that, in actions under § 1194 to recover unpaid minimum wages, the IWC's wage orders did generally define the employment relationship, and thus who might be liable. An examination of the wage orders' language, history, and place in the context of California wage law, moreover, made clear those orders did not incorporate the federal definition of employment. In the instant case, neither of the produce merchants "suffered or permitted" plaintiffs to work because neither had the power to prevent plaintiffs from working. The undisputed facts showed that the direct employer alone controlled plaintiffs' wages, hours, and working conditions. No evidence suggested the direct employer's employees viewed the produce merchants' field representatives as their supervisors or believed they owed their obedience to anyone but the direct employer and his foremen.

Outcome

The court affirmed the judgment of the court of appeal.

LexisNexis® Headnotes

 

 

Business & Corporate Compliance > ... > Wage & Hour Laws > Scope & Definitions > Minimum Wage

Labor & Employment Law > Wage & Hour Laws > Remedies > Private Suits

HN1  Minimum Wage

Lab. Code, § 1194, provides in part that, notwithstanding any agreement to work for a lesser wage, any employee receiving less than the legal minimum wage or the legal overtime compensation applicable to the employee is entitled to recover in a civil action the unpaid balance of the full amount of this minimum wage or overtime compensation, including interest thereon, reasonable attorney fees, and costs of suit. § 1194, subd. (a). The legislature has thus given an employee a cause of action for unpaid minimum wages without specifying who is liable. That only an employer can be liable, however, seems logically inevitable as no generally applicable rule of law imposes on anyone other than an employer a duty to pay wages.

 

Governments > Legislation > Interpretation

HN2  Interpretation

A court's fundamental task in construing a statute is to ascertain the intent of the lawmakers so as to effectuate the purpose of the statute. In this search for what the legislature meant, the statutory language itself is the most reliable indicator, so the court starts with the statute's words, assigning them their usual and ordinary meanings, and construing them in context. If the words themselves are not ambiguous, the court presumes the legislature meant what it said, and the statute's plain meaning governs. On the other hand, if the language allows more than one reasonable construction, the court may look to such aids as the legislative history of the measure and maxims of statutory construction. In cases of uncertain meaning, the court may also consider the consequences of a particular interpretation, including its impact on public policy.

 

Labor & Employment Law > Wage & Hour Laws > Scope & Definitions > Definition of Employ

Business & Corporate Compliance > ... > Wage & Hour Laws > Scope & Definitions > Minimum Wage

Labor & Employment Law > Wage & Hour Laws > Remedies > Private Suits

HN3  Definition of Employ

In actions under Lab. Code, § 1194, to recover unpaid minimum wages, the Industrial Welfare Commission's wage orders do generally define the employment relationship, and thus who may be liable. An examination of the wage orders' language, history and place in the context of California wage law, moreover, makes clear that those orders do not incorporate the federal definition of employment.

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49 Cal. 4th 35 ; 231 P.3d 259 ; 109 Cal. Rptr. 3d 514 ; 2010 Cal. LEXIS 4660 ; 75 Cal. Comp. Cases 430; 16 Wage & Hour Cas. 2d (BNA) 408

MIGUEL MARTINEZ et al., Plaintiffs and Appellants, v. CORKY N. COMBS et al., Defendants and Respondents.

Subsequent History: As Amended May 20, 2010.

Reported at Martinez v. Combs, 2010 Cal. LEXIS 5612 (Cal., May 20, 2010)

Time for Granting or Denying Rehearing Extended Martinez (Miguel) v. Combs (Corky N.), 2010 Cal. LEXIS 5757 (Cal., June 7, 2010)

Modified by Martinez v. Combs, 2010 Cal. LEXIS 5036 (Cal., June 9, 2010)

Modified by Martinez (Miguel) v. Combs (Corky N.), 2010 Cal. LEXIS 5111 (Cal., June 9, 2010)

Rehearing denied by, Request denied by Martinez v. Combs, 2010 Cal. LEXIS 6274 (Cal., June 30, 2010)

Prior History:  [1] Superior Court of San Luis Obispo County, No. CV001029, Earle Jeffrey Burke, Judge. Court of Appeal, Second Appellate District, Division Six, No. B161773.

Martinez (Miguel) v. Combs (Corky N.), 2010 Cal. LEXIS 2086 (Cal., Mar. 1, 2010)

Disposition:  The court affirmed the judgment of the court of appeal.