Naranjo v. Spectrum Security Services. Inc., No. S258966, 2022 WL 1613499 (Cal. May 23, 2022)
Summary: Unpaid meal- and rest-break premiums may serve as the basis for waiting-time penalties and inaccurate wage statement claims. Read our in-depth analysis of this case here.
Morgan v. Sundance Inc., 142 S.Ct. 1708 (May 23, 2022)
Summary: The FAA does not require a party resisting arbitration on the grounds of waiver to show they suffered prejudice from a failure to compel arbitration sooner.
Facts: Plaintiff Robyn Morgan worked at a Taco Bell franchise owned by Defendant Sundance Inc. Plaintiff signed an agreement to arbitrate any employment dispute with Defendant. Despite that agreement, Plaintiff filed a nationwide collective action asserting that Defendant violated federal law regarding overtime pay. Defendant initially defended against the lawsuit, filing a motion to dismiss and engaging in mediation. Nearly eight months after Plaintiff filed the lawsuit, Defendant moved to stay the litigation and compel arbitration under the Federal Arbitration Act (“FAA”). Plaintiff opposed, arguing that Defendant had waived its right to arbitrate by litigating for so long. The district court denied Defendant’s motion. The Court of Appeals for the Eighth Circuit reversed, finding that because Plaintiff had failed to show prejudice, it could not find that Defendant had waived its right to compel arbitration. The United States Supreme Court granted certiorari to resolve a circuit split...
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