California Employer’s Good Faith Defense to Wage Statement Penalties Recognized by State’s Supreme Court

On May 6, 2024, the California Supreme Court issued its decision in Naranjo v. Spectrum Security Services, Inc., Case No. S279397, handing California employers a significant victory. The court unanimously held that a good faith dispute defense applies to claims for penalties or damages for inaccurate wage statements under California Labor Code Section 226(e). The Naranjo decision, in a rare win for California employers, resolves a split in authority in the California Courts of Appeal and enables employers who act in good faith to defend against inaccurate wage statement penalties under Section 226(e). Note: Duane Morris served as appellate counsel for Spectrum in this case.

Read the full Alert on the Duane Morris LLP website.

New York Federal Court Grants Class Certification In Pay Discrimination Litigation

By Gerald L. Maatman, Jr., Jennifer A. Riley, and Michael DeMarino

New York City The Big AppleDuane Morris Takeaways – In Chalmers, et al. v. City of New York, 22 Civ. 3389 (S.D.N.Y. Sept. 19, 2022), Judge Analisa Torres of the U.S. District Court recently certified a Title VII class action alleging race discrimination in pay for various positions involving fire protection inspectors in the City’s Fire Department. The decision in Chalmers is an important one for employers, as shows how plaintiffs’ class action lawyers are using certification theories to “work around” the seemingly impregnable barrier to class certification based on Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338 (2011). Corporate counsel are well-served to heed the lessons of Chalmers in crafting their approaches to dealing with workplace class action litigation. Continue reading “New York Federal Court Grants Class Certification In Pay Discrimination Litigation”

Introducing The Duane Morris Class Action Defense Blog


Duane Morris is proud to announce the launch of its Class Action Defense blog! Watch this space for information, insights and analysis on the latest cases and trends from some of the nation’s most experienced attorneys in defending class actions and bet-the-company cases. For more on the transformational expansion of Duane Morris’ class action defense capabilities, please see the press release on our new colleagues Jerry Maatman, Jen Riley and their team joining our firm. Welcome to Duane Morris!

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The opinions expressed on this blog are those of the author and are not to be construed as legal advice.

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