Lauren Teukolsky is set to speak at the Los Angeles County Bar Association’s 45th annual Labor & Employment Law Section Symposium. The LACBA symposium will take place on Wednesday, March 19 at the Biltmore Hotel in downtown Los Angeles from 8:30 am to 5:00 pm.  Ms. Teukolsky will speak on a panel alongside Tritia Murata, Partner at Davis Wright Tremaine LLP, Cynthia Sandoval, mediator at Sandoval Mediation, and Todd Ratshin, Deputy Secretary of Enforcement at the California Labor & Workforce Development Agency (LWDA).
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The panel will discuss the changes made to Private Attorney General Act (PAGA) law in the past year, including the recent appellate decisions about “headless” PAGA cases, the introduction of the early evaluation conference process, the limitations on violations that plaintiffs can assert, and the greater number of violations that employers can cure. The panel will reflect on how these changes impact their work and approach to PAGA litigation. Speakers will also touch on the state of wage-and-hour laws ranging from healthcare workers’ minimum wage to protections for child social media influencers.

Ms. Teukolsky has worked to protect employees’ rights for over two decades and speaks regularly at conferences on employment law. Earlier this month, Ms. Teukolsky spoke at the  Berkeley Law School Conference on Gender Discrimination and Harassment Law about a new federal law that excludes sexual harassment claims from arbitration. She recently spoke about PAGA at the UCLA Law Women LEAD conference, and moderated a session at CELA’s (California Employment Lawyer Association) Annual Employment Law Conference on individual wage-and-hour arbitrations. Her commentary on the latest developments in employment law is regularly featured by major publications such as Bloomberg Law, Law360, Law.com, and the Los Angeles Times.

To register for the LACBA Symposium on March 19, click here.  If you believe you’ve been treated unlawfully in the workplace and want to get in touch with our office, click here.

Lauren Teukolsky was recently quoted in a Daily Journal article and a Bloomberg Law article about a recent 2nd District Court of Appeal opinion halting the growing trend of “headless” PAGA cases. The Private Attorney Generals Act (PAGA) permits employees to act as deputies of the state and bring a suit on behalf of themselves and other aggrieved employees to enforce the Labor Code. A “headless” PAGA case is one in which the plaintiff disclaims all individual claims and seek PAGA penalties solely on behalf of other aggrieved employees. Plaintiffs typically engage in this practice to avoid mandatory arbitration of individual claims and the resulting delay in their PAGA case.

This practice grew in popularity after the California Court of Appeals issued Balderas v. Fresh Start Harvesting in April 2024, holding that workers who disclaim their individual claims can still bring a group PAGA action on behalf of other aggrieved employees. But in December 2024, a different division of the California Court of Appeals ruled in Leeper v. Shipt that a PAGA action on behalf of others necessarily includes an individual PAGA claim for the plaintiff, and the individual claim can be compelled to arbitration while the PAGA claim remains stayed in court.

The Daily Journal quoted Ms. Teukolsky saying if Leeper remains good law, “it is the end of the headless PAGA case.” She adds that, “there’s going to be a huge wave of defendants fling motions for reconsideration of lower court decisions that have allowed such lawsuits to proceed.” Bloomberg Law noted Ms. Teukolsky’s analysis of twenty post-Balderas court orders found that a majority denied motions to compel arbitration based on Balderas. She noted that “Given the sheer number of cases involving the headless PAGA issue, it seems likely that other courts of appeal will weigh in, and eventually the California Supreme Court will take one of these cases to clarify the law.”
Ms. Teukolsky has represented workers for over two decades and her commentary on the latest developments in employment law is regularly featured by major publications such as Bloomberg Law, Law360, Law.com, and the Los Angeles Times.

To read the Daily Journal article, click here.  To read the Bloomberg Law article, click here.  If you believe you’ve been treated unlawfully in the workplace and want to get in touch with our office, click here.

Lauren Teukolsky’s “Wage and Hour Case Notes” were published in the November 2024 edition of the CLA California Labor and Employment Law Review. Her column describes three recent decisions from California’s Supreme Court and appellate courts that affect wage-and-hour law.

Ms. Teukolsky’s column discusses whether Proposition 22’s classification of Uber and Lyft drivers as independent contractors is constitutional, and whether courts can approve PAGA settlements even when there are multiple overlapping PAGA cases. Her column also explores whether public entities are subject to California’s Labor Code provisions for rest and meal breaks.

California Lawyers Association (CLA) is a voluntary statewide bar association. Its mission is to “promote excellence, diversity and inclusion in the legal profession and fairness in access to justice and the rule of law.”  Ms. Teukolsky was recently appointed to serve on the Executive Committee of CLA’s Labor & Employment Section.  Her three-year term started in October 2024.

Ms. Teukolsky has written for CLA’s California Labor and Employment Law Review for over two years. Her “Wage and Hour Case Notes” are published on an alternating quarterly basis. Ms. Teukolsky has represented workers for over two decades and her commentary on the latest developments in employment law is regularly featured by major publications such as Bloomberg Law, Law360, Law.com, and the Los Angeles Times.

​If you would like to speak with Ms. Teukolsky about a wage-and-hour matter, click here.

​Earlier this month, Bloomberg Law quoted Lauren Teukolsky in an article about the California Supreme Court’s recent ruling in Naranjo v. Spectrum Security Services.  The case involved a security guard who was provided with on-duty meal breaks.  After Spectrum fired him for leaving his post for a meal break, Naranjo sued for missed meal break premiums.  He sought an hour of premium pay for each day he missed a break.  After many years of litigation, the California Supreme Court held in a 2022 decision that Naranjo was permitted to seek penalties under Labor Code 226, which requires employers to provide accurate pay stubs listing all wages earned in a pay period.  Spectrum’s failure to list premium pay for missed breaks could entitle Naranjo to 226 penalties if Spectrum’s violation was “knowing and intentional.”

In the most recent California Supreme Court decision, issued on May 7, 2024, the Court held that Spectrum’s violations were not “knowing and intentional” because it reasonably believed in good faith that it had a defense to the requirement to pay missed meal premiums. 

The Court held that “if an employer reasonably and in good faith believed it was providing a complete and accurate wage statement in compliance with the requirements of section 226, then it has not knowingly and intentionally failed to comply with the wage statement law.” Going forward, employees will likely need to prove one of three things to recover 226 penalties: (1) the employer’s failure to report wages or hours on a pay stub was made in bad faith; (2) the employer’s defense was objectively unreasonable; or (3) the employer’s defense was unsupported by any evidence. 

In the Bloomberg Law article, Ms. Teukolsky discusses the significance of the ruling for California’s workers:

“The ruling isn’t ‘a death sentence’ for the ability of workers to recoup California wage and hour penalties, but it does place ‘a slightly higher burden on plaintiffs who want to recover those penalties,’ said Pasadena-based employee-side attorney Lauren Teukolsky.”
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The article continues:

“’I don’t think it signals a shift in thinking among the California Supreme Court,’ Teukolsky said. ‘I view it as an incremental change in the standards that govern the imposition of penalties under California law. It’s not a sea change.’

Bloomberg Law’s article also includes thoughts from Ms. Teukolsky on how plaintiff-side employment attorneys will need to adapt to the Court’s ruling. Naranjo’s potential impact on PAGA claims is also discussed. 

Ms. Teukolsky has represented workers for over two decades and her commentary on the latest developments in employment law is regularly featured by major publications such as Law360, Law.com, and the Los Angeles Times. Most recently, Ms. Teukolsky was quoted in a February Bloomberg Law article on the Ninth Circuit’s opinion in Johnson v. Lowe’s Home Centers, LLC.
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To read Bloomberg Law’s article in its entirety, click here. To get in touch with our office, click here. 

Lauren Teukolsky will speak on a panel for the Alameda County Bar Association’s (ACBA) Labor and Employment Symposium on Friday, September 15th. The panel is titled, “In Viking River’s Wake: Two Supreme Courts on the Future of PAGA,” and will focus on the viability of PAGA actions following the US Supreme Court’s opinion in Viking River and the California Supreme Court’s decision in Adolph v. Uber Technologies.

Ms. Teukolsky will appear on the panel alongside Arthur Gaus, a partner at Kaufman Dolowich. The pairing will allow viewers to hear analysis from an employee’s perspective, represented by Ms. Teukolsky, and an employer’s perspective, represented by Mr. Gaus.

Ms. Teukolsky’s commentary on both Viking River and Adolph v. Uber has been featured in a variety of publications, including Bloomberg Law, Daily Journal and Law.com. She also previously discussed the cases on panels presented by the Beverly Hills Bar Association, Los Angeles County Bar Association, and California Employment Lawyer Association.
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The panel will take place over Zoom in addition to several other panels being presented at the ACBA symposium. For more information on the panels and how to view them, click here. For more information on Ms. Teukolsky’s work and her firm, click here. 

Lauren Teukolsky will speak on a Beverly Hills Bar Association (BHBA) webinar on August 22 on the future of California’s Private Attorneys General Act (PAGA) following the state’s highly anticipated Supreme Court ruling in Adolph v. Uber Technologies, Inc.. Chris Jalian, a Partner at Paul Hastings, LLP, will join Ms. Teukolsky on the webinar. Nazgole Hashemi, Co-Founder of LegalAxxis, Inc., will serve as moderator for the event.

The webinar will examine what the Adolph v. Uber ruling means for employees and employers, with Ms. Teukolsky representing the employees’ perspective and Mr. Jalian representing the employers’ perspective.  In the ruling, the Court held that California’s workers could continue to pursue PAGA labor claims on behalf of their coworkers even if their individual labor claims were forced into arbitration. Experts considered the ruling to be a big win for the state’s workers.

Ms. Teukolsky’s commentary on Adolph v. Uber was previously featured in several articles by Bloomberg Law and Law.com.

The BHBA’s Labor and Employment section will present the webinar. The section provides a forum for labor and employment attorneys and neutrals to network, share ideas, and learn about the latest issues and trends in the field.
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The webinar will take place on Tuesday, August 22 from 12:30 pm to 1:30 pm PT via ZOOM. To register, click here.