Seyfarth Synopsis: The California
Supreme Court recently determined that meal and rest period premium
payments are subject to the final pay timing requirements of Labor
Code section 203 and the wage statement reporting requirements of
Labor Code section 226(e). Additionally, the prejudgment interest
rate for violating these sections is seven percent. Naranjo v.
Spectrum Security Services, Inc.
Facts
On June 4, 2007, Gustavo Naranjo filed a putative class action
on behalf of Spectrum Security Services, Inc.'s
California-based non-exempt employees, alleging that Spectrum
failed to pay him meal and rest premium pay pursuant to Labor Code
section 226.7, and that Spectrum's failure to do so resulted
in violations of Labor Code section 203 for failing to pay all
wages owed upon separation of employment, as well as Labor Code
section 226(e) for failing to furnish accurate wage statements.
