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Naranjo v. Spectrum: Meal Break Claims Allowed Despite SCA
The case of Naranjo v. Spectrum Security Services, Inc. examined the interplay between federal law under the Service Contract Act (SCA) and California labor statutes. The California Court of Appeal considered whether federal preemption barred claims under the state’s Labor Code, ultimately remanding the case for further proceedings on certain claims.
Background of the Case
Gustavo Naranjo, a detention officer for Spectrum Security Services, filed a class action lawsuit alleging violations of California labor laws. Naranjo contended that Spectrum failed to provide required meal and rest breaks and accurate wage statements and sought additional compensation and penalties under the California Labor Code.
Spectrum argued that the SCA, which governs wages and benefits for employees of federal contractors, preempted Naranjo’s state law claims. The trial court granted summary judgment in favor of Spectrum, finding that the SCA provided the exclusive remedies for such claims. Naranjo appealed.
Key Legal Issues
- Does the SCA Preempt State Labor Claims?
The SCA mandates minimum wages and fringe benefits for employees of federal contractors but does not explicitly address state wage laws. Spectrum claimed that the SCA preempted state labor claims under doctrines of conflict and field preemption.
The Court of Appeal rejected this argument, holding that the SCA does not preempt state labor laws consistent with its goals. The court noted that California’s labor statutes, such as those requiring meal and rest breaks, provide additional protections that complement the SCA rather than conflict with it.
- Can State Claims Proceed Alongside Federal Requirements?
The court determined that California Labor Code claims for additional wages, penalties for late payment, and record-keeping violations did not undermine the SCA’s regulatory scheme. These claims aligned with the SCA’s objectives by promoting fair compensation and transparency.
Court’s Findings and Conclusion
The Court of Appeal reversed the trial court’s summary judgment on several of Naranjo’s state law claims, concluding that:
- Naranjo’s claims for additional wages under Labor Code Section 226.7 were not preempted because they addressed higher wages required by state law rather than the minimums mandated by the SCA.
- Penalties for late payments under Section 203 and record-keeping violations under Section 226 complemented the SCA’s goals and could proceed in state court.
- The SCA did not bar Naranjo’s state claims, as federal law explicitly allowed for compliance with additional state wage laws.
The case was remanded for further proceedings on Naranjo’s Labor Code claims.
Conclusion
The Naranjo decision reinforces the ability of state labor laws to coexist with federal regulations like the SCA. Employers operating under federal contracts should ensure compliance with both state and federal labor requirements to avoid liability.
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