Ruelas v. County of Alameda
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A group of non-convicted individuals detained at the Santa Rita Jail in Alameda County, California, filed a lawsuit against the county and a private contractor, Aramark Correctional Services, LLC. The detainees were working in the jail's kitchen, preparing meals for the jail population and staff under an agreement between the county and Aramark. They were not paid for their labor. The detainees sued for failure to pay minimum wage and overtime.
The case was initially heard in a federal district court, which granted in part and denied in part the defendants' motions to dismiss. The court reasoned that while the Penal Code addresses employment and wages of state prisoners, it does not address such matters for pretrial detainees confined in county jails. The court also agreed with the County that government entities are exempt from state overtime laws and therefore granted the County's motion to dismiss the claim for overtime wages. The district court certified for interlocutory appeal the legal question of pretrial detainees’ entitlement to minimum and overtime wages.
The Supreme Court of California was asked by the United States Court of Appeals for the Ninth Circuit to decide whether non-convicted incarcerated individuals working in a county jail for a private company have a claim for minimum wage and overtime under California law. The Supreme Court of California concluded that non-convicted incarcerated individuals performing services in county jails for a for-profit company do not have a claim for minimum wages and overtime under Section 1194 of the California Labor Code, even in the absence of a local ordinance prescribing or prohibiting the payment of wages for these individuals.
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