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Constitutional Law
Equal Protection
Unlawful Bill of Attainder

Fowler Packing Company Inc., Gerawan Farming Inc. v. David M. Lanier, in his official capacity as Secretary of the California Labor and Workforce Development Agency; Christine Baker, in his official capacity as the Director of the Department of Industrial Relations; Julie A. Su, in her official capacity as California Labor Commissioner

Published: Aug. 13, 2016 | Result Date: Jul. 7, 2016 | Filing Date: Jan. 1, 1900 |

Case number: 1:16-cv-00106-DAD-SAB Bench Decision –  Dismissal

Court

USDC Eastern


Attorneys

Plaintiff

David A. Schwarz
(Sheppard, Mullin, Richter & Hampton LLP)


Defendant

Kamala D. Harris

Thomas M. Patton
(California Department of General Services)

Mark R. Beckington
(California Department of Justice)


Facts

Fowler Packing Company Inc. and Gerawan Farming Inc. filed a complaint against Labor and Workforce Development Agency Secretary David Lanier, Industrial Relations Director Christine Baker, and Labor Commissioner Julie Su, in connection with Assembly Bill 1513, codified as Labor Code Section 226.2.

Contentions

PLAINTIFFS' CONTENTIONS:
The 2015 Assembly Bill 1513 codified case decisions held that California minimum wage law requires that piece rate workers receive at least minimum wage for rest and recovery periods and other non-productive time. Plaintiffs contended that specified parts of the bill targeted plaintiffs for punishment by establishing time and subject matter limitations that make certain amnesty provisions of the bill unavailable to plaintiffs. Plaintiffs sued alleging the bill violates their rights to equal protection and constitutes an unlawful Bill of Attainder.

DEFENDANTS' CONTENTIONS:
Defendants disputed that the bill imposes any punishment and contended that the challenged provisions are rationally related to legitimate purposes. Defendants contended that plaintiffs could not meet their burden of negating all conceivable rational reasons for the challenged time and subject matter limitations. Defendants therefore moved to dismiss for failure to state a claim, and asserted lack of standing and 11th amendment immunity from suit.

Result

The court granted the motion to dismiss, concluding that the bill passes rational basis scrutiny and that the complaint therefore failed to state a cognizable claim.

Other Information

FILING DATE: Jan. 22, 2016.


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