Do California Labor Code Minimum Wage & Overtime Provisions Apply to Work Programs?

In a recent California Wage and Hour case, the court considered whether or not California’s Labor Code minimum wage and overtime provisions apply to specific inmates in county jail work programs.

The Case: Ruelas v. Cnty. of Alameda

The Court: Supreme Court of California

The Case No.:S277120

The Plaintiffs: Ruelas v. Cnty. of Alameda

The plaintiffs in the case are non-convicted individuals who were detained at the Santa Rita Jail in Alameda County, California. While detained at the Santa Rita Jail, the plaintiffs were assigned to prepare meals for the jail’s general population and staff in the jail’s kitchen under an agreement between Aramark, a private contractor, and the County of Alameda. The plaintiffs were not paid for their work and filed an employment law complaint citing minimum wage and overtime violations.

The Allegations: Employment Law Protections

A minimum wage violation occurs when an employer pays an employee at a pay rate lower than the minimum wage rate required by federal, state, or local law. The minimum wage is determined at the federal level by the Fair Labor Standards Act (FLSA) in the U.S., but states and local governments can set higher minimum wage rates. Employers are required to provide the highest applicable minimum wage, whether federal, state, or local. Minimum wage violations can result in legal penalties, including the payment of back wages, damages to the affected employees, fines, and sometimes criminal charges against the employer.

An overtime violation occurs when an employer does not properly compensate eligible employees for hours worked beyond the standard workweek limits defined by law. In the U.S., the Fair Labor Standards Act (FLSA) is the federal law governing overtime pay rates, although some states have their own overtime laws that may offer greater protections. Under the FLSA, overtime pay is required for eligible employees (non-exempt workers) at a rate of one and one-half times their regular pay rate for all hours worked over 40 in a workweek.

The Defendant: Ruelas v. Cnty. of Alameda

The plaintiffs filed an employment law complaint against the county and private contractor Aramark Correctional Services, LLC. The defendants argue that the law grants discretion to the Board of Supervisors regarding whether to pay wages.

The Case: Ruelas v. Cnty. of Alameda

Initially, the Federal District Court granted in part and denied in part, the defendant’s motion to dismiss, arguing that the Penal Code addresses issues of employment and wages for state prisoners but that it does not address the same issues for non-convicted detainees awaiting trial in county jails. At the same time, the court also agreed with the Defendants’ argument that government entities are exempt from state overtime laws and dismissed the plaintiff’s claim for overtime pay. After the district court certified the question for interlocutory appeal, the United States Court of Appeals for the Ninth Circuit asked the California Supreme Court to decide the issue: do non-convicted incarcerated individuals working for a private company while in a county jail have a legal claim for minimum wage and overtime pay under California law?

Do Non-Convicted Incarcerated Individuals Have a Legal Claim for Minimum Wage & Overtime Pay?

Ruelas v. Cnty. of Alameda is pending before the federal Ninth Circuit Court of Appeals, but the federal court asked the California Supreme Court to address the state law question first. To determine their finding on the issue, the court considered the interplay among the Penal Code, the California Labor Code, and the constitutional provisions governing public-private inmate labor contracts. The Supreme Court of California concluded that non-convicted incarcerated individuals working for a for-profit company while in county jails do not have a claim for minimum wages and overtime pay under California Labor Code Section 1194 (even in the absence of a local ordinance prescribing or prohibiting the payment of wages for these individuals).

If you have questions about filing a California wage and hour or overtime lawsuit, please contact Blumenthal Nordrehaug Bhowmik DeBlouw LLP. Experienced employment law attorneys are ready to assist you in various law firm offices in San Diego, San Francisco, Sacramento, Los Angeles, Riverside, and Chicago.