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Huerta V CSI Electrical – Synopsis

by | Jun 19, 2024 | Employment Law

Real and ordinary construction worker on his job.

A groundbreaking ruling by the California Supreme Court in the case of Huerta v. CSI Electrical Contractors has recently put the spotlight on California’s Wage and Hour Laws. This pivotal case interpreted key wage order provisions under Industrial Welfare Commission (IWC) Wage Order No. 16 in favor of the workers, essentially changing the face of compensable hours and employer-mandated travel rules for on-site occupations in numerous industries, including construction and drilling.

CSI Electrical Contractors found themselves in a legal battle following workers’ contention regarding unpaid hours. Plaintiff George Huerta, alongside several other workers, was employed by CSI to provide construction services at a solar power facility. The workers claimed that they were not compensated for the time spent waiting at the security gate at either end of their working day, and their 30-minute meal periods, where they were not allowed to leave the site.

Ultimately the California Supreme Court ruled in favor of the construction workers affirming that CSI needed to compensate the workers for time spent going through security and time spent on meal breaks.

If your employer owes you wages for compensable time contact our team of employment lawyers can help.

Details of the Huerta V. CSI Electrical Case

Huerta and his co-workers would start their day waiting at a security gate, where security would scan their badges and search their vehicles. After going through this mandatory process, a further 15-minute drive was required to reach their workstation. The situation was the same at the end of the workday, with a 10–30-minute delay experienced while exiting the facility. Due to the presence of endangered species, employees were mandated to drive at a maximum speed of 20mph on the access road.

For these extra hours at the beginning and end of the day, Huerta and his coworkers claimed they weren’t compensated. Consequently, they filed a class-action lawsuit against CSI. The case saw the corridors of the U.S. District Court for the Northern District of California and was moved to the Ninth Circuit.

The Ninth Circuit court posed three well-framed questions for interpretation surrounding Wage Order No. 16 to the California Supreme Court. These questions sought clarity on whether the time spent on the employer’s premises was compensable under Wage Order No. 16, whether the time spent driving from the security gate to the parking lots was compensable as “hours worked” or “employer-mandated travel,” and whether unpaid “meal period” under a qualifying Collective Bargaining Agreement (CBA) is nonetheless still compensable as “hours worked” when workers are relieved from duty but prevented from leaving the premises.

The Supreme Court delved into the legal fabric of Wage Order No.16. The Justices examined the “hours worked” provision, which underlined two clauses forming the basis for the determination of compensable hours – the “control clause” and the “suffered or permitted to work clause.”

Swinging the gavel in favor of Huerta and his co-workers, the Supreme Court held that the time workers spent going through the security procedure and the meal break was compensable as “hours worked” within the meaning of Wage Order No. 16. The Court cited previous judgments and pointed out four pillars that culminated in this decision. Specifically, CSI held stringent control over employees during this time, confining them to a specific location, and requiring them to perform specific tasks. Further, these activities were pegged as being in the interest of CSI, rather than workers’ benefits.

Navigating the second question posed by the Ninth Circuit, the California Supreme Court acknowledged that the time spent traveling from the security gate to the workstations might be compensable as “employer-mandated travel,” only if it meets certain criteria. For time to qualify as “employer-mandated travel,” it must be borne out of the employer’s command and direction and serve an employment-related purpose other than mere access to the worksite.

Lastly, addressing the third question the Supreme Court held that unpaid “meal periods” in a qualifying CBA are still compensable as “hours worked”, even when employees aren’t explicitly performing tasks, but are prevented from leaving the premises.

Impact of Huerta V CSI Electrical

For employees in California, especially those in on-site occupations, Huerta v. CSI Electrical Contractors is indeed a milestone case. Its positive influence extends beyond the construction sector, potentially broadening the scope of what may be considered compensable time in other industries. This landmark ruling underlines the importance of ensuring that employers adhere to the state’s labor laws and reinforces the power of wage orders in safeguarding the rights of employees.

How Shimoda & Rodriguez Law, PC Can Help

Here at Shimoda & Rodriguez Law, PC we are committed to pursuing justice for those who’ve been unfairly compensated by employers in violation of any wage and hour-related laws. If you believe that your employment rights, as outlined in the Industrial Welfare Commission Wage Order No. 16 or any other Wage Order, have been breached, reach out to us. Our experienced attorneys stand ready to fight for your rights and secure the compensation you deserve.