​Lauren Teukolsky’s “Wage and Hour Case Notes” were published in the March 2025 edition of the CLA California Labor and Employment Law Review. Her column describes two recent decisions from the Supreme Court of the United States and California’s appellate court that affect wage-and-hour law.

Ms. Teukolsky’s column discusses a new U.S. Supreme Court opinion about an employer’s required burden of proof to classify workers as exempt from the overtime requirements of the Fair Labor Standards Act. The column also discusses Leeper v Shipt, a recent California appellate decision addressing the “headless” PAGA phenomenon. The court held that a PAGA plaintiff may not disclaim individual relief to avoid arbitration. On February 26, a different California appellate panel criticized Leeper, holding that “headless” PAGA cases are permitted. Ms. Teukolsky predicts the California Supreme Court will soon address “headless” PAGA cases given the split of authority.

California Lawyers Association (CLA) is a voluntary statewide bar association. 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.

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).
​
The panel will discuss the changes made to Private Attorneys 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’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.

Lauren Teukolsky was recently quoted in a Bloomberg article about the increasing use by California employees of “headless” PAGA cases to avoid being forced to arbitrate their wage-and-hour claims. 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.  In 2022, the United State Supreme Court ruled that employers may not require employees to waive PAGA claims via a mandatory arbitration agreement.  But the Court also ruled that employers can require employees to split their “individual PAGA claim” from the claim on behalf of others, and to arbitrate the individual claim.

​A headless PAGA case is one in which the plaintiff disclaims all individual claims, including the individual PAGA claim, and files the lawsuit to seek PAGA penalties solely on behalf of other aggrieved employees.  This strategy was galvanized 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.  While Balderas was not about arbitration, several plaintiffs’ lawyers have seized on the holding of the case to file headless PAGA cases in an effort to stay out of arbitration. 

​As stated in the Bloomberg article, Ms. Teukolsky’s analysis of 20 post-Balderas orders reveals that the majority of trial courts are following Balderas and permitting PAGA plaintiffs who disclaim individual claims to avoid arbitration.  A small but significant minority are distinguishing Balderas and still requiring PAGA plaintiffs to arbitrate their “aggrieved employee” status.  The Bloomberg article quoted Ms. Teukolsky saying, “Given this split, I anticipate we will see more decisions from the Court of Appeals in the next year or two about whether a PAGA plaintiff can stay out of arbitration by disclaiming all individual claims.”

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 article in its entirety, 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 July 2024 edition of the CLA California Labor and Employment Law Review. Her column describes five recent decisions from California’s Supreme Court and appellate courts that affect wage-and-hour law. Among the decisions are rulings regarding minimum wage for pretrial detainees, arbitration agreements that exclude PAGA claims, and the standard for awarding penalties for inaccurate paystubs.

Ms. Teukolsky’s column also discusses whether employees without individual PAGA claims have standing to pursue PAGA claims on behalf of others, and whether employers waive their right to arbitration of individual PAGA claims if they do not move to compel arbitration in a timely manner.

CLA (California Lawyers Association) 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 starts 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.

Wage-and-hour law is an ever-evolving field with frequent rulings that regularly reshape the legal landscape. Ms. Teukolsky has navigated those rulings for over 20 years and is an expert in both state and federal wage-and-hour law. She speaks frequently on wage-and-hour topics at national and state conferences and is regularly quoted by media outlets for her insights on the topic.

To read Ms. Teukolsky’s article in its entirety, click here. If you would like to speak with Ms. Teukolsky about a wage-and-hour matter, click here.

Earlier this week, Lauren Teukolsky was appointed to the California Lawyers Association (CLA) Labor & Employment section’s Executive Committee. CLA is a statewide bar association with a mission to “promote excellence, diversity and inclusion in the legal profession and fairness in access to justice and the rule of law.”

The Executive Committee for CLA’s Labor and Employment Section plays a vital role in carrying out the sections’ basic functions in addition to collaborating on delivering programs, publications, services, and benefits to section members.

Executive Committee appointees are nominated by current Executive Committee members. Appointees are evaluated for their accomplishments and their proven commitment to volunteer work that demonstrates a commitment to public service, among other criteria.

Ms. Teukolsky regularly contributes to CLA’s California Labor and Employment Law Review, where her “Wage and Hour Case Notes” are published on an alternating quarterly basis.
​
Ms. Teukolsky’s three-year appointment on the Executive Committee will begin on September 8, 2024. 

Lauren Teukolsky’s “Wage and Hour Case Notes” were published in the March 2024 edition of the CLA California Labor and Employment Law Review. Ms. Teukolsky’s column describes three recent decisions from California and federal appellate courts that affect wage-and-hour law. Among the decisions are rulings regarding trial courts’ authority (or lack thereof) to strike “unmanageable” PAGA claims, and whether a policy requiring employees to remain on work premises during rest breaks merits class certification.

CLA (California Lawyers Association) 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’s “Wage and Hour Case Notes” are published on a quarterly basis by CLA’s Labor and Employment Law Section.

Wage-and-hour law is a dynamic field with new appellate decisions that regularly reshape the legal landscape. Ms. Teukolsky has navigated those appellate decisions for over 20 years and is an expert in both state and federal wage-and-hour law. She speaks frequently on wage-and-hour topics at national and state conferences and is regularly quoted by media outlets for her insights on the topic.

To read Ms. Teukolsky’s article in its entirety, click here. If you would like to speak with Ms. Teukolsky about a wage-and-hour matter, click here. 

Lauren Teukolsky’s “Wage and Hour Case Notes” were published in the November 2023 edition of the California Labor and Employment Law Review. Ms. Teukolsky’s column describes seven new decisions from California and federal appellate courts that affect wage-and-hour law. Among the cases are significant rulings regarding reimbursements for pandemic era work-from-home expenses, arbitration exemptions for transportation workers, time entry rounding, and one of the first appellate applications of Adolph v. Uber, among other topics.

Wage-and-hour law is an ever-changing field with new appellate decisions that often reshape the legal landscape. Ms. Teukolsky has navigated those appellate decisions for over 20 years and is an expert in both state and federal wage-and-hour law. She speaks frequently on wage-and-hour topics at national and state conferences and is regularly quoted by media outlets for her insights on the topic.

The 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’s “Wage and Hour Case Notes” are published on a quarterly basis by CLA’s Labor and Employment Law Section.

To read Ms. Teukolsky’s article in its entirety, click here. If you would like to speak with Ms. Teukolsky about a wage-and-hour matter, click here. 

Lauren Teukolsky will speak on an October 26th panel at the California Lawyers Association’s (CLA) 13th Annual Advanced Wage and Hour Conference. The panel will explore the effects of Viking River Cruises and Adolph v Uber on the legal landscape, particularly with respect to wage-and-hour arbitrations. Ms. Teukolsky will represent the plaintiff’s perspective while co-panelist Jason Kearnaghan, a partner at Sheppard Mullin, will represent the defendant’s views.

The two panelists will explain how to draft and attack arbitration agreements, how to arbitrate individual PAGA claims, and the upsides and downsides of wage-and-hour arbitration for plaintiffs and defendants, among other topics.

Ms. Teukolsky regularly discusses the latest employment law developments at conferences and panels. In September and October, Ms. Teukolsky shared insights on Viking River Cruises and Adolph v Uber for a trio of talks hosted by the Alameda County Bar Association, the Beverly Hills Bar Association, and the California Lawyers Association. Her commentary on the two cases has also been featured in articles by the Daily Journal, Bloomberg Law and Law.com.

CLA is a nonprofit, voluntary bar association serving thousands of licensed attorneys throughout California. Its Labor and Employment Law Section serves as a networking and educational forum for California’s labor and employment lawyers and non-lawyers with an interest in the field. 
​
To register for CLA’s 13th Annual Advanced Wage and Hour Conference, click here. For more information about Teukolsky Law, click here. 

Lauren Teukolsky’s “Wage and Hour Case Notes” were published in the March 2023 edition of the California Labor and Employment Law Review, describing six new decisions from California and U.S. appellate courts that affect wage-and-hour law. The column discusses arbitration agreements with wholesale PAGA waivers, California’s “outside salesperson” exemption, and the state’s first published appellate court decision to discuss Viking River’s impact on a motion to compel arbitration in a PAGA case, among other topics.

Wage-and-hour law is a dynamic field, with new appellate decisions that regularly reshape the legal landscape.  Ms. Teukolsky is an expert in California wage-and-hour law and federal wage-and-hour law, and speaks frequently on wage-and-hour topics at national and state conferences. Her “Wage and Hour Case Notes” are published on a quarterly basis by the California Lawyers Association’s (CLA) Labor and Employment Law Section.

CLA is a voluntary 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.”

To read Ms. Teukolsky’s article in its entirety, click here. If you would like to speak with Ms. Teukolsky about a wage-and-hour matter, click here to get in touch.