Summary of a Recent
Judicial
Development in
Labor
Plaintiffs Stated Valid Claims for AWPA
and State Labor Law Violations
Walt McCarterNational AgLaw Center Research Associate
Summary of Decision
In Valenzuela v. Giumarra Vineyards Corp., 614 F. Supp. 2d 1089, 2009 WL 900735 (E.D. Cal. 2009), the United States District Court for the Eastern District of California held that the plaintiffs had stated valid claims under the Agricultural Workers Protection Act, the California Labor Code, and the Unfair Competition Law, and well as state law claims for breach of contract.
Background
Former employees of Giumarra Vineyards Corporation (Giumarra), a commercial table grape grower, brought this action against Giumarra for violations of the federal Migrant and Seasonal Agricultural Workers Protection Act (AWPA), 29 U.S.C. §§ 1801-1872; breach of contract; failure to pay overtime wages; failure to reimburse work expenses; failure to provide required meal periods as required by the Industrial Welfare Commission Work Order 14 (IWC Order 14-2001) and Cal. Labor Code § 226.7; failure to provide required rest periods as required by the IWC Order 14-2001 and Cal. Labor Code § 226.7; failure to keep accurate employee wage statements; failure to pay wages in a timely manner at the termination of employment; and violation of the Unfair Competition Law (UCL), Cal. Bus. & Prof. Code § 17200 et seq. Id. at *1. The defendant moved to dismiss the complaint. Id.
Arguments
The defendant argued that the plaintiffs had failed to state an AWPA cause of action, that there was no remedy for IWC Order 14-2001 meal and rest period violations under Cal. Labor Code § 226.7, and that the plaintiffs failed to state a breach of contract claim, a waiting time claim, or a UCL claim. Id. It also argued that the court should decline to assert supplemental jurisdiction over the state law claims, and that the UCL restricted the plaintiffs' recovery to injunctive relief and restitution. Id.
Analysis and Holdings
The court explained that it had federal question jurisdiction over the plaintiffs' AWPA claims, and it would assume supplemental jurisdiction over closely interrelated issues. Id. at *2. The court found that IWC Order 14-2001 clearly required employers to provide both meal and rest periods within the meaning of Cal. Labor Code § 226.7(b), and held that the plaintiffs could bring a private suit for recovery for § 226.7 violations. Id. at *9-10. The court further found that the plaintiffs had clearly articulated a claim for breach of contract, and that that their "allegations of discharge from seasonal agricultural work state[d] a claim under California's waiting time penalty laws." Id. at *10, *12. The court agreed with the defendant's assertion that the UCL only allowed for injunctive relief and restitution, but clarified that "payments under § 226.7 are restitutionary because they are akin to payment of overtime wages to an employee: both are 'earned wages' and thus recoverable under the UCL." Id. at *12. The court therefore denied the defendant's motion to dismiss. Id.
The case was decided on March 31, 2009.