In May 2022, the California Supreme Court issued its decision in Naranjo v. Spectrum Security Systems, which considered the issue of whether failing to pay premium wages for meal and rest period violations gave rise to claims for waiting time penalties or violations of wage statement requirements.

The underlying action was a class action brought by former and current employees of Spectrum Security for meal period violations. The class sought waiting time penalties and penalties for failure to provide accurate wage statements.

The California Supreme Court remanded the matter to the California Court of Appeals to consider two issues:

  1. Whether the trial court erred in finding Spectrum Security had not acted “willfully” in failing to timely pay employees premium pay, which barred recovery of waiting time penalties.
  2. Whether Spectrum Security’s failure to report missed-break premium pay on wage statements was “knowing and intentional” to allow recovery of penalties for failure to provide accurate wage statements.

The Court of Appeal concluded as to the first question that the substantial evidence supported the trial court’s finding that Spectrum Security presented defenses at trial in good faith for its failure to pay meal premium to departing employees and therefore its failure was not “willful” to entitle employees to waiting time penalties.

As to the second question the Court of Appeal held that because Spectrum Security had a good faith belief that it was in compliance with wage statement requirements, the trial court was precluded from finding the violation was “knowing and intentional” and awarding penalties.

While the outcome was good for Spectrum Security, the path to the decision was extremely fact specific based on the defenses presented by Spectrum Security at separate phases of trial, including that the class members were not covered by California labor law because they worked on federal enclaves and/or performed federal functions.

Helpfully in the decision, the Court of Appeal reiterated that the regulations interpreting the California statute for waiting time penalties do not conflict with the statute but act to define terms not defined in the statute. The regulations specifically state that a “good faith dispute” that any wages are due occurs when an employer presents a defense, based on law or fact which if successful, would preclude any recovery on the part of the employee.

Moreover, the Court of Appeal interpreted the knowing and intentional language when it comes to penalties as being willful based on similar language in other statutes that willful is intentional and rejected some federal district court interpretations to the contrary.

If you have questions about this case or related issues, contact a Jackson Lewis attorney to discuss.

This year, employers in California have updated pay data reports to submit to the state’s Civil Rights Department (CRD).  Senate Bill (SB) 1162, passed in 2022, updated previous employee pay data reporting obligations and created an entirely new obligation to pay data reporting related to “employees hired through labor contractors.”  This year, these pay data reports are due by May 10th.

In January, the state issued Frequently Asked Questions to assist employers to navigate these new requirements—in particular regarding the requirement to submit pay data reports on “labor contractor employees.”

California’s initial guidance was that “labor contractor employees” included only workers

  1. “on a labor contractor’s payroll,”
  2. “for whom labor contractor is required to withhold federal social security taxes from that individual’s wages,” and
  3. “who performs labor for a client employer within the client employer’s usual course of business.” 

Because the phrase “who performs labor of a client employer within the client employer’s usual course of business” was not defined, many employers and commentators reasonably interpreted the reporting to be limited to workers who are involved with the actual functioning or immediate support of the employer’s business. 

This interpretation includes, for example, administrative augmentation, information technology support, call center workers, and contract labor performing the same work as the company’s employees.  But it would exclude ancillary workers, such as overnight custodial staff, parking attendants, and groundskeepers from “labor contractor employee” pay data reporting.

However, the California Civil Rights Department (CRD) updated its Frequently Asked Questions Page on February 22, 2023.  One of CRD’s new FAQs clarifies that the CRD believes “the client employer’s usual course of business” is far broader than most understood. 

What is “labor . . . within the client employer’s usual course of business,” such that workers performing that labor are “labor contractor employees” who must be reported on?

A “labor contractor” is an individual or entity that supplies, either with or without a contract, a client employer with workers to perform labor within the client employer’s usual course of business. Gov. Code. § 12999(k)(2).

A client employer’s “usual course of business” means the regular and customary work of the client employer. “Regular and customary work” means work that is performed on a regular or routine basis that is either part of the client employer’s customary business or necessary for its preservation or maintenance. “Regular and customary work” does not include isolated or one-time tasks.

Example: Farmworkers contracted seasonally to pick fruit for a client employer’s farm would be performing work within the client employer’s usual course of business because the work is performed on a routine basis and is part of the client employer’s customary business.

Example: Janitorial staff performing nightly cleaning and general maintenance of a client employer’s premises would be performing work within the employer’s usual course of business because the work is performed on a regular basis and is necessary for the maintenance of the client employer’s customary business.

Example: Catering staff contracted to serve food at a trucking company’s tenth anniversary party would not be performing work within the client employer’s usual course of business, assuming catering a party is an isolated occurrence for the company.

Example: Accountants hired to perform an external audit of a fitness company’s financial statements would not be performing work within the client employer’s usual course of business, assuming financial auditing is an isolated occurrence for the company.

An individual performing work within the client employer’s usual course of business is a labor contractor employee if that individual is on a labor contractor’s payroll and the labor contractor is required to withhold federal social security taxes from that individual’s wages. For more information, see the FAQs “Which employers are required to submit Labor Contractor Employee Reports to CRD?” and “For Labor Contractor Employee Reports, what is the ‘Snapshot Period?’”

This new guidance shifts the focus away from the substance of the worker’s contribution to the client employer’s business.  Instead, the critical question becomes whether the function is (a) “performed on a regular or routine basis” and (b) “either part of the client employer’s customary business or necessary for its preservation or maintenance.”  Moreover, the examples make clear that CRD intends workers like custodial staff should be included in the annual labor contractor pay data report. 

This new FAQ will require employers to revisit their pay data reporting plans.  Under this new guidance, far more “workers” may be “labor contractors” who must be included in the reporting.

Jackson Lewis attorneys will continue to monitor California’s pay data reporting and other pay equity issues. If you have questions about compliance with California’s pay data reporting contact a Jackson Lewis attorney to discuss.

It is well-known that California law is often more strict than federal law. Just as California handles overtime differently than the federal Fair Labor Standards Act (FLSA), California law also treats aspects of overtime exemptions differently than the FLSA. One such difference is the Outside Salesperson exemption.

Under the FLSA, an outside sales employee is exempt if they meet the following test:

  • The employee’s primary duty must be making sales (as defined in the FLSA), or obtaining orders or contracts for services or for the use of facilities for which a consideration will be paid by the client or customer; and
  • The employee must be customarily and regularly engaged away from the employer’s place or places of business.

California’s requirements for outside salespersons are different. Under the California Labor Code and  California Wage Orders, an outside salesperson is defined as follows:

  • Any person, 18 years of age or over;
  • Who customarily and regularly works more than half (more than 50 percent) the working time away from the employer’s place of business
  • Selling tangible or intangible items or obtaining orders or contracts for products, services, or use of facilities.

Essentially, unlike the FLSA’s qualitative standard, California law sets a quantitative standard. Stated differently, under California law, the amount of time a salesperson spends doing various tasks, and where the activity takes place, must be considered when assessing the employee’s exemption status.

If you have questions about the outside salesperson exemption or related issues, contact a Jackson Lewis attorney to discuss.

While the State of California and several cities across the state increased their minimum wages on January 1, 2023, some cities—including the City of Los Angeles—will increase their minimum wage in July 2023.

On February 1, 2023, the City of Los Angeles Office of Wage Standards announced the coming increase for July 1, 2023. Based upon the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPA-W) for the Los Angeles metropolitan area, the minimum wage for the City of Los Angeles will increase by $0.74 for a new minimum wage rate of $16.78 per hour.

The City of Los Angeles’ minimum wage ordinance applies to employees who in any particular week perform at least two hours of work within the geographic boundaries of Los Angeles for their employer and are entitled to payment of minimum wage under California law.

The Office of Wage Standards has also published the required posting on their website: https://wagesla.lacity.org/

To ensure your company has up-to-date minimum wage information, subscribe to Jackson Lewis’ Minimum Wage Watch, which provides alerts on changes in the minimum wage in California and around the country.

If you have questions about complying with state or local minimum wage laws, contact a Jackson Lewis attorney to discuss.

February 17th was not only the start of the President’s Day weekend but also the last day that California legislators could introduce bills for consideration during the 2023 legislative session. Jackson Lewis attorneys will be monitoring the below bills, which have the potential for a profound impact on California employers.

Assembly Bill (AB) 1100 – Four-Day Workweek

AB 1100  states that it will be amended to include provisions to establish a four-day workweek. Upon amendment, the bill would likely alter the conditions for the accrual of overtime, similar to a bill that failed last year.

Senate Bill (SB) 703 – Flexible Work Schedules

SB 703 would enact the California Workplace Flexibility Act of 2023. Under this bill, a nonexempt employee could request a flexible work schedule of workdays up to 10 hours per day in a 40-hour workweek and an employer could implement this schedule without the obligation to pay overtime compensation for hours worked over 8 hours in a workday. This proposed bill is styled like California’s Alternative Workweek Schedules but on an individual basis.

Assembly Bill (AB) 524 – Protection for Family Caregivers

AB 524 would amend the Fair Employment and Housing Act (FEHA) to prohibit employment discrimination against employees with family caregiver obligations. This legislation is similar to a bill that failed last year protecting “family responsibilities.”

Senate Bill (SB) 731 – Remote Work as an Accommodation

SB 731 would authorize an employee with a qualifying disability to initiate a renewed reasonable accommodation request to perform their work remotely if certain requirements are met, including that the employee performed their essential job functions remotely for at least 6 of the 24 months preceding the renewed request.

Senate Bill (SB) 525 – Minimum Wage for Health Care Workers

SB 525 mirrors efforts from last summer in several cities to pass increased minimum wage requirements for health care workers. Under the proposed bill, workers for covered health care facilities, including hospitals and skilled nursing care facilities, would be paid a mandated minimum wage of $25 starting January 1, 2024 and to increase annually.

Senate Bill (SB) 616 – Additional Paid Sick Leave Days

SB 616 would amend California’s statewide paid sick leave requirements by changing accrual methods and increasing the total amount of sick leave an employee may accrue annually from 24 hours (3 days) to 56 hours (7 days), with a maximum accrual of 112 hours (14 days).

Jackson Lewis will continue to track legislation that affects employers doing business in California. If you have questions about any of the bills in this article or related issues, contact a Jackson Lewis attorney to discuss.

In October 2022, Governor Newsom announced the California COVID-19 State of Emergency would end on February 28, 2023. While this will phase out some of the tools the state used in handling the COVID-19 pandemic, it does not mean the end of all COVID-19 regulations and requirements for employers.  Three illustrative examples are discussed below.

Supplemental Paid Sick Leave

As employers may know, the statewide supplemental paid sick leave expired at the end of 2022. Following Governor Newsom’s lead, the City of Los Angeles has rescinded its local emergency, which has caused its supplemental paid sick leave requirement to sunset effective February 15, 2023. Similarly, the City of Long Beach has voted to sunset its local supplemental paid sick leave effective February 21, 2023.

Some local supplemental paid sick leave ordinances, however, have remained in place. The City of Oakland is considering extending its local emergency which would extend the requirements of its local supplemental paid sick leave. Additionally, the County of Los Angeles has not indicated when it will end its local emergency, which means its supplemental paid sick leave will remain in effect for unincorporated areas of the county.

Moreover, San Francisco voters approved the Public Health Emergency Leave Ordinance, which provides paid leave for employees for “public health emergencies” which currently include COVID-19, in the city.

Cal/OSHA Regulations and Requirements

On February 3, 2023, Cal/OSHA’s COVID-19 Prevention Non-Emergency Regulations went into effect.  The regulations will apply to California employers for two years, except for the recordkeeping requirements which will expire in three years.

Moreover, in 2022, a bill was passed to extend COVID-19 employee notice requirements until 2024. Previously under Assembly Bill 685 which was passed in 2020, if an employer received notice of potential exposure to COVID-19, the employer was required to provide written notice of the potential exposure within one business day to all employees who were at the worksite.  Originally, this notification requirement was set to expire on January 1, 2023. Assembly Bill 2693 extends this notification requirement to January 1, 2024 and gives employers another option for complying with these notification requirements. 

Right of Recall

In 2021, California passed Senate Bill 9 which required that covered employers offer employees laid off due to the COVID-19 pandemic available positions based on a preference system. This law sunsets on January 1, 2024. Several cities across the state have passed similar right of recall ordinances which remain in effect despite the end of the state of emergency.

If you have questions about your COVID-19 obligations in California, please reach out to a Jackson Lewis attorney to assist.

A pair of recent California Court of Appeal decisions serve as yet another reminder to employers of the difficulties that they potentially face when enforcing arbitration agreements in California and, as a result, the importance of drafting clear, precise arbitration agreements.  The first case, Hernandez v. Meridian Management Services, LLC, reiterated the importance of clearly identifying third-party beneficiaries of an arbitration agreement, and the second case, Murrey v. Superior Court, provides another example of how California courts scrutinize what may otherwise appear to be reasonable arbitration rules.

Hernandez – Identify Your Third-Party Beneficiaries

Parties that are not signatories to an arbitration agreement may still, in certain circumstances, enforce the agreement to compel arbitration when litigation arises. This situation often arises when an employee signs an arbitration agreement with their employer, and the agreement covers not only claims asserted against the employer but also claims asserted against the employer’s parent, subsidiaries, or related companies. But in order for a non-signatory to invoke an arbitration agreement as a third-party beneficiary, the agreement must clearly evidence the signing parties’ intent to cover that non-signing party. This was the hard lesson learned in Hernandez.           

In Hernandez, the plaintiff was a customer service representative for Intelex. As part of her hiring process, she signed an arbitration agreement with Intelex. At the same time, she worked for several other entities related to Intelex. These other entities purportedly were jointly owned and operated, and allegedly shared payroll, human resources, legal, and risk management teams with Intelex. After her termination, the plaintiff brought employment claims against all the other entities but did not name Intelex as a defendant to the lawsuit in what was likely a strategic move by the plaintiff to avoid arbitration.

The other entities attempted to compel arbitration pursuant to the arbitration agreement that the plaintiff signed with Intelex. The other entities argued that, among other things, they could enforce Intelex’s arbitration agreement with the plaintiff as third-party beneficiaries. In doing so, the other entities highlighted the fact that the plaintiff alleged that all the companies, including Intelex, were commonly owned and essentially operated as a “single organism with no meaningful division between them except on paper.”

Both the trial and appellate courts disagreed. The appellate court explained the test for determining whether a party is a third-party beneficiary of an agreement as follows:

[E]xamine the express provisions of the contract at issue, as well as the relevant circumstances of the contract’s formation, to determine not only (1) whether the third party would benefit from the contract, but also (2) whether a motivating purpose of the contracting parties was to provide a benefit to the third party, and (3) whether permitting a third party to bring its own breach of contract action against a contracting party would be consistent with the objectives of the contract and the reasonable expectations of the contracting parties.

Here, notwithstanding all the companies purportedly being jointly owned and operated, the court concluded that the other entities were not identified in the arbitration agreement and there was no indication in the agreement that Intelex and the plaintiff sought to benefit the other entities. Further, while there was mention in the agreement that it would cover Intelex’s “agents,” the court found that the other entities were not acting as Intelex’s “agents.” Control is the essential ingredient for agency, the court explained, and there was an insufficient showing that Intelex controlled the actions of the other entities despite their purportedly sharing employees.

The Takeaway: Related companies – even those that are intimately intertwined – cannot simply assume that one company’s arbitration agreements can cover others. To ensure coverage of a non-signatory, the agreement should clearly identify the non-signatory and express a clear intent to cover the non-signatory. It is a simple point, but one that is often overlooked.

Murrey – Review Your Arbitration Rules from Any Perceived Unfairness

In Murrey, the appellate court reversed the grant of a motion to compel arbitration on the grounds of unconscionability. Some of the bases on which the appellate court found unconscionability are not surprising. For example, the court complained that the rules potentially impose discovery costs on an employee that the employee would not have incurred had the dispute been heard in court and excluded claims that were more likely to be asserted by the employer from arbitration. This is generally in line with settled California law on these issues. However, the appellate court went out of its way to go further and concluded that some arbitration rules and provisions, while reasonable on their face, could nevertheless result in some degree of unfairness to the employee.  

First, notwithstanding the employer’s explanation that it uses a nationally recognized third party (the American Arbitration Association) to administer its arbitrations and thereby supplements its rules with the American Arbitration Association’s arbitration rules, the appellate court faulted the employer for not identifying the arbitration administrator in the agreement or its own rules at the outset. Rather, the employer retained the sole authority to select the third-party administrator (and therefore the corresponding rules). According to the court, this resulted in a surprise to the employee and could work to the employee’s disadvantage since the employer could choose the arbitration administrator based on what was advantageous to defending against the employee’s asserted claims.  

Second, despite acknowledging that the arbitration rules gave the arbitrator discretion to grant the parties additional discovery depending “on the facts of the particular claim” and what the arbitrator “consider[ed] necessary for a full and fair exploration of the issue,” the appellate court took issue with the rules’ default discovery limitations. Specifically, the rules afforded each party three depositions, 20 interrogatories, 15 requests for documents, and 15 requests for admission. Although the rules gave the arbitrator discretion to grant additional discovery, according to the court this still fell short. The court stated that employment cases can be complex and the very fact that the default rules started from a point of limitation was enough to find some degree of unfairness to employees – even if an arbitrator has the discretion to allow additional discovery.

Third, despite noting that limitations on an arbitration hearing are “not per se unconscionable,” the appellate court concluded that the arbitration rule in this case, which limited the hearing to 16 hours and five witnesses per party, “clearly favor[ed]” the employer given that the plaintiff asserted ten causes of action that were “factually complicated and difficult to prove.”

Fourth, despite acknowledging that confidentiality in arbitration is “not per se unconscionable,” the appellate court found that confidentiality in the context of the plaintiff’s sexual harassment claims “serve[d] no purpose other than to benefit” the employer by “keeping [any] past findings [of sexual harassment] secret.” This, in the court’s view, “undermines an employee’s confidence in the fairness and honesty of the arbitration process” and potentially discourages employees from pursuing valid claims.

The Takeaway: Employers must anticipate that courts will place their arbitration agreements under a withering spotlight. Therefore, employers should regularly review their arbitration agreements to ensure that its provisions – even those that appear reasonable on their face – do not result in any perceived unfairness to employees.

 If you have questions about these cases or issues related to arbitration agreements, contact a Jackson Lewis attorney to discuss.

California employers take note: the non-emergency version of the Cal/OSHA COVID-19 Prevention regulations are now in effect.

At the end of 2022, the Cal/OSHA Standards Board voted to adopt the COVID-19 Prevention non-emergency regulations to replace the Emergency Temporary Standard(ETS).

On February 3, 2023, the California Office of Administrative Law approved the non-emergency standard. Though not titled a temporary standard, the non-emergency standard is set to sunset two years from its effective date, with the exception of the recordkeeping requirements which will expire in three years.

In conjunction with the approval, Cal/OSHA published both a Frequently Asked Question Page (FAQ) and a COVID-19 Model Prevention Program.

The FAQ covers the following:

  • Scope of Coverage
  • COVID-19 Prevention Addressed in the Injury and Illness Prevention Program
  • Determining Measures to Prevent COVID-19 Transmission; Identifying and Correcting COVID-19 Hazards
  • Face Coverings and Personal Protective Equipment
  • Ventilation
  • Vaccines
  • Training
  • Addressing COVID-19 Cases in the Workplace
  • Testing
  • Outbreaks
  • Recordkeeping and Reporting
  • CDPH Isolation and Quarantine

The FAQs provide some useful information as employers pivot from the ETS requirements.

Hybrid/Remote Employees

The non-emergency regulations apply only when employees work at the workplace or are exposed at work, and not when they work from home. The regulations do not apply to employees who are assigned to telework and who choose to work somewhere other than their home e.g. a hotel or a rental property unless arranged by the employer as employer-provided housing. Additionally, these regulations do not apply to employees who are covered by the Aerosol Transmissible Diseases regulation.

Close Contact Definition

The non-emergency regulations continue to use the revised definition of “close contact” set forth by the California Department of Public Health (CDPH) in October 2022.

  1. In indoor spaces of 400,000 or fewer cubic feet per floor, a close contact is defined as sharing the same indoor airspace as a COVID-19 case for a cumulative total of 15 minutes or more over a 24-hour period during a COVID-19 case’s infectious period.
  2. In large indoor spaces greater than 400,000 cubic feet per floor, a close contact is defined as being within 6 feet of the COVID-19 case for a cumulative total of 15 minutes or more over a 24-hour period during the COVID-19 case’s infectious period.
  3. Offices, suites, rooms, waiting areas, break or eating areas, bathrooms, or other spaces that are separated by floor-to-ceiling walls are considered distinct indoor airspaces.

The FAQs also provide a formula for determining the cubic feet of an indoor space.

Face Coverings and Personal Protective Equipment

Under the non-emergency regulations, employers must provide face coverings and ensure they are worn when required by CDPH.

Additionally, all employers must provide and ensure face coverings are worn during outbreaks at the workplace, as well as ensure the use of face coverings when employees return to work after having COVID-19 or after a close contact.

Testing Requirements

Under the non-emergency regulation, employers must offer testing at no cost and during paid time:

  • To employees who had a close contact at work, with an exception for symptom-free employees who recently recovered from COVID-19.
  • During an outbreak, to all employees within an exposed group, at least once a week, except for employees who were not at work during the relevant period and symptom-free employees who recently recovered from COVID-19.
  • During a major outbreak, twice per week, except for employees who were not at work during the relevant period and symptom-free employees who recently recovered from COVID-19 (returned cases).

Benefits to Excluded Workers

The non-emergency regulation no longer includes an exclusion pay requirement. Though the Standards Board discussed in December holding a vote to amend the regulations to include exclusion pay, that has not proceeded to date and was not indicated for the Board’s upcoming meeting on February 16th. The FAQs indicate that employees who test positive may be eligible for other benefits such as state disability.

Jackson Lewis will continue to track COVID-19 regulations and requirements into the endemic phase. If you have questions about the Cal/OSHA COVID-19 Standards or related workplace safety issues, please reach out to the Jackson Lewis attorney with whom you often work or any member of our Workplace Safety and Health Team.

On January 20, 2023, San Francisco approved the Military Leave Pay Protection Act, which mandates that certain employers must provide paid leave for employees taking leave for military duty.

The ordinance takes effect 30 days after passage on February 19, 2023.

Covered Employers

The ordinance applies to employers who employ 100 or more employees, regardless of location, but excludes the City of San Francisco as well as other governmental employers.

Covered Employees

The ordinance applies to any employee of a covered employer who (1) works within the geographic boundaries of San Francisco, including part-time and temporary employees; and (2) is a member of the reserve corps of the United States Armed Forces, National Guard, or other uniformed service organization of the United States.

Supplemental Compensation

Under the ordinance, while on covered military leave, employers must pay covered employees the difference between the amount of the employee’s gross military pay and the gross pay the employer would have paid the employee had the employee worked their regular work schedule. When calculating the employee’s gross pay, covered employers are not required to include overtime unless the overtime is scheduled as part of the employee’s regular work schedule.

Covered employees may take the leave in daily increments for one or more days at a time, for up to 30 days in any calendar year.

Limits on Supplemental Compensation

The ordinance does include limits on the leave taken, including the following:

  1. The supplemental compensation the employer is required to pay the employee can be offset by amounts paid under any other law or employer military leave policy so that the employee does not receive excessive payments for the leave time taken.
  2. If an employee is able to return to work but does not do so within 60 days of release from military duty, the employer may treat any supplemental compensation paid to the employee during the employee’s military leave as a loan to the employee to be repaid, with interest, to the employer under the terms of the ordinance.

Collective Bargaining Waiver

The ordinance does not apply to employees covered by a bona fide collective bargaining agreement if the collective bargaining agreement expressly waives the ordinance’s requirements.

If you have questions regarding the San Francisco Military Leave Pay Protection Act or related issues, contact a Jackson Lewis attorney to discuss.

On January 24, 2023, the California Secretary of State completed its verification process and qualified a referendum challenging Assembly Bill (AB) 257, also known as the FAST Recovery Act for the November 2024 ballot. In the meantime, the law will not take effect unless it is approved by voters in the November 2024 election.

Governor Newsom signed AB 257 into law in September 2022. If it ultimately goes into effect, it will establish a Fast Food Council comprising fast food employees, worker advocates, franchisors, franchisees, and government officials within the Department of Industrial Relations that will set industry-wide standards for wages, working hours, and other working conditions related to the health, and safety of fast food workers.

At the end of 2022, a coalition of California small business owners, restaurateurs, franchisees, and related entities filed suit to block enforcement of the law pending the Secretary of State’s determination on whether the referendum attempt would qualify. Earlier this month, the coalition was successful in obtaining a preliminary injunction against enforcement.  

The FAST Recovery Act referendum will join other employment-related ballot measures in 2024, including one seeking to reform California’s Private Attorney General Act (PAGA) and another seeking to increase the state minimum wage.

Jackson Lewis will continue to track changes in state legislation affecting employers. If you have questions about the FAST Recovery Act or related issues contact a Jackson Lewis attorney to discuss.