Procedural Posture

Appellant California Department of Industrial Relations sought review of the judgment from the Superior Court of Alameda County (California), that entered summary judgment and awarded attorney’s fees in favor of respondent corporation in appellant’s action for respondent’s breach of a settlement agreement and failure to pay wages pursuant to Cal. Lab. Code § 96.7.

Overview

Appellant California Department of Industrial Relations negotiated a settlement agreement with respondent corporation for reimbursement for the cost of uniforms respondent had required its employees to furnish in violation of Cal. Code Regs. tit. 8, § 11070(9)(A). Appellant sought recovery for breach of the settlement agreement when respondent refused to comply. Both appellant and respondent sought summary judgment and the trial court granted respondent’s motion because the agreed payments for uniform expenses reimbursement constituted neither wages or monetary benefits under Cal. Lab. Code § 96.7. Appellant sought review. The appellate court found that Cal. Lab. Code § 200 provided for a broad definition of wages and the benefit payments at issue were wages. The appellate court reversed the summary judgment and award of attorney’s fees in favor of respondent because § 96.7 authorized the appellant to take whatever actions were required to collect and deposit unpaid wages and as an agency of the state and the statutorily authorized trustee for the employees of respondent, appellant had the power to negotiate the checks on behalf of the employees.

Outcome

A critical undetermined issue presented to labor law lawyer San Diego who as acting as court’s referee was continued for a later motion. The appellate court reversed the order of summary judgment and award of attorney’s fees in favor of respondent corporation because respondent’s agreement with appellant California Department of Industrial Relations for payments for employee uniform expense reimbursement constituted wages and appellant was statutorily authorized to take whatever actions were necessary to collect and deposit the unpaid wages.

Procedural Posture

Appellant challenged judgment of the Superior Court of Los Angeles County (California), which ruled against appellant on his action seeking partition and accounting of a joint tenancy, and ruled in favor of one appellee’s cross-complaint seeking a declaration of appellant as a constructive trustee.

Overview

A couple orally promised appellee child that if he stayed with them and worked, he would receive the bulk of their estates when they died. Upon appellee child’s compliance, the couple placed their property in joint tenancy and executed wills leaving the majority of their property to appellee child. However, one member of the couple secretly revised his will, leaving his part of joint tenancy to appellant. After the couple’s death and the probation of the wills, appellant brought an action for partition. The trial court found that appellant was a constructive trustee of the property he received as a breach of the couple’s agreement with appellee child. Appellant argued that the statute of frauds barred enforcement of the oral agreement. The court held that appellee’s detrimental reliance on the terms of the agreement, combined with the unjust enrichment that would result if the agreement were invalidated, estopped appellant’s use of the statute of frauds to strike the agreement.

Outcome

The judgment was affirmed because appellant’s share in the joint tenancy was the result of a breach of an oral contract.