General Atomics v. Super. Ct.Annotate this Case
Tracy Green sued her employer, General Atomics, based on its alleged failure to provide accurate, itemized wage statements showing “all applicable hourly rates in effect during the pay period and the corresponding number of hours worked at each hourly rate by the employee.” Green maintained that General Atomics “failed to identify the correct rate of pay for overtime wages” because its wage statements showed “0.5 times the regular rate of pay rather than 1.5.” General Atomics moved for summary judgment, contending its wage statements complied with the statute because they showed the total hours worked, with their standard rate or rates, and the overtime hours worked, with their additional premium rate. The trial court issued an order denying the motion. General Atomics challenged that order by petition for writ of mandate. The Court of Appeal concluded the trial court erred by determining that General Atomics’ wage statements violated Labor Code section 226: “While other formats may also be acceptable, given the complexities of determining overtime compensation in various contexts, the format adopted by General Atomics adequately conveys the information required by statute. It also allows employees to readily determine whether their wages were correctly calculated, which is the central purpose of section 226.” The Court therefore granted the petition for writ of mandate.