Rodriguez v. Taco Bell Corp., No. 16-15465 (9th Cir. 2018)
Annotate this CaseThe Ninth Circuit affirmed the district court's grant of summary judgment to Taco Bell in a putative class action alleging that employees should be compensated under California law for the time spent on the company's premises eating discounted meals during meal breaks. As a preliminary matter, the panel held that plaintiff's dismissal with prejudice created a valid final judgment for purposes of jurisdiction under 28 U.S.C. 1291. On the merits, the panel held that Taco Bell did not violate California Wage Order 5–2001, because the employees were free to use the thirty minutes in any way they wished, subject only to the restriction that if they purchased a discounted meal, they had to eat it in the restaurant. The panel held that Taco Bell’s meal policy satisfied the standard set forth in Brinker Restaurant Corp. v. Superior Court, 273 P.3d 513 (Cal. 2012), because the company relieved employees of all duty and relinquished control over their activities. Even assuming the regular rate claim was not completely derivative of plaintiff's meal break claim and referred to overtime hours worked apart from meal breaks, and even assuming further that the value of the meal could be considered part of her compensation, she has not established that value.
Court Description: California Employment Law. The panel affirmed the district court’s judgment in favor of Taco Bell Corp. in a putative class action concerning employee meal breaks. After the district court granted summary judgment to Taco Bell on most of plaintiff’s claims, the court granted plaintiff’s request that the district court dismiss the remaining pending claim. As a threshold jurisdictional issue, the panel held that the dismissal with prejudice created a valid final judgment for purposes of 28 U.S.C. § 1291. California Wage Order 5-2001 requires employees be relieved of all duty during a requisite meal period. During plaintiff’s period of employment, Taco Bell offered thirty- minute meal breaks that were fully compliant with California’s requirements, but with a special offer that employees could purchase a meal from the restaurant at a discount, provided they ate the meal in the restaurant. The panel held that California law was not violated because Taco Bell relieved their employees of all duties during the meal break period and exercised no control over their activities, where employees were free to use the thirty minutes in any way they wished, subject only to the restriction that if they purchased a discounted meal, they had to eat in the restaurant. The panel rejected plaintiff’s RODRIGUEZ V. TACO BELL 3 contention that employees were under sufficient employer control to render the time compensable. The panel also rejected plaintiff’s assertion that the value of the discounted meals be added to the regular rate of pay for overtime purposes.
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