Parsons v. Estenson Logistics, LLC

Summary

The California Court of Appeal affirmed summary judgment for Estenson Logistics in a PAGA action challenging its practice of paying weekly wages on the Monday following a Saturday deadline. The court held that Code of Civil Procedure section 12a extends the Labor Code section 204(d) payment period when the seventh calendar day falls on a weekend or holiday.

Holdings

1. Code of Civil Procedure section 12a applies to the time limit in Labor Code section 204, subdivision (d), because section 12a expressly applies to provisions of law in any code or statute requiring an act to be performed within a specified period of time.
2. When weekly-paid wages are due under Labor Code section 204, subdivision (d), on a weekend or holiday, the employer may pay them on the next day that is not a holiday.
3. Summary judgment for Estenson was proper because the relevant facts were undisputed and its payment practice did not violate Labor Code section 204, subdivision (d), as construed with Code of Civil Procedure section 12a.

Questions Presented

1. Whether Code of Civil Procedure section 12a applies to the seven-calendar-day wage-payment period in Labor Code section 204, subdivision (d).
2. Whether wages due under Labor Code section 204, subdivision (d), on a Saturday, Sunday, or holiday may be paid on the next day that is not a holiday.
3. Whether summary judgment for Estenson was proper on the undisputed facts.

Disposition

affirmed