California court rules employer must report extra pay for missed breaks on pay stubs

When both sides appealed, the Court of Appeal upheld the trial court’s decision that the company had breached meal break laws, but reversed its finding that non-payment of bonuses meal breaks could support claims under the wage statement and timely payment provisions. The Court of Appeal reduced the prejudgment interest rate to 7%.

The California Supreme Court reversed the judgment of the Court of Appeals insofar as it determined that failure to timely pay or declare the Section 226.7 premium could not warrant relief under Sections 203 and 226. The Supreme Court sent the case back to the Court of Appeal for a new trial. .

Additional payments for missed breaks were counted as wages, which must be reported on wage statements required during employment under Section 226 and must be paid within statutory time limits when an employee has quit. his employment under Section 203, the Supreme Court ruled.

According to the Supreme Court, the extra pay is intended to compensate both for the unlawful deprivation of a guaranteed break and for the work the employee performed during the break period. Finally, the 7% default rate set by the California Constitution applied to prejudgment interest for amounts owed for failure to provide meal and rest breaks.