Crestwood Behavioral Health, Inc. v. Superior Court
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Fragoza filed suit under the Private Attorneys General Act (Lab. Code 2698) in Alameda County Superior Court, alleging that she formerly worked for Crestwood in Solano County and that Crestwood systematically violates the Labor Code at its treatment centers located throughout California by neglecting to properly compensate non-exempt employees for all hours worked; failing to provide accurate and itemized wage statements; failing to allow non-exempt employees to take rest/meal breaks or to pay premiums for missed breaks; and failing to timely pay wages owed on termination. She sought civil penalties (Lab. Code 2699(a), (f)) on behalf of the state and aggrieved Crestwood employees. Crestwood moved to transfer venue to Sacramento County (where its principal place of business is located), arguing that venue is not proper in Alameda County because Fragoza worked only in Solano County.
The trial court denied the motion, concluding that Alameda County is a proper venue under either Code of Civil Procedure section 3931 or section 395.5 because Crestwood is a corporation and operated two facilities in Alameda County, which “is a county ‘where the obligation or liability arises.” The court of appeal denied Crestwood mandamus relief. The allegations regarding Fragoza’s employment with Crestwood
are necessary to establish standing, not venue.
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