In Alfredo Sanchez v. Miguel Martinez, the Court of Appeal, Third Appellate District, held that although an employee who is not authorized and permitted to take a paid 10-minute rest break in compliance with California law may assert a claim for either unpaid wages or seek one additional hour of pay (i.e., a rest break premium) under Labor Code Section 226.7, the employee cannot recover damages under both theories. All California employers will find this case instructive, as it may also provide a basis to argue against similar "double recovery" and/or "stacking" of penalties predicated on other Labor Code violations.
Factual and Procedural Background
In Sanchez v. Martinez, a group of farm laborers who pruned grapes and were compensated on a piece-rate for each grape vine pruned, filed a wage-hour lawsuit alleging various claims including an alleged failure to have been permitted paid rest breaks. The laborers contended they were not paid their piece-rate ' or any wage rate ' during their rest breaks. In the lawsuit, they pursued a theory of double-recovery, seeking both minimum wage damages for the actual unpaid break time and an additional rest break premium under Section 226.7. Following a trial on the merits and an initial judgment in favor of the employer, an appeal and a partial reversal by the Court of Appeal as to the rest break claim, and then on remand a finding in the laborers' favor, the trial court awarded the laborers $416 in damages and $17,775 in civil penalties. The trial court awarded these damages solely based upon Section 226.7 and...
