 The California Court of Appeal recently issued a significant decision in Lorenzo v. San Francisco Zen Center, ruling that the "ministerial exception" does not shield religious organizations from minimum wage lawsuits. The case involved Annette Lorenzo, a former staff member at the San Francisco Sōtō Zen Buddhist church. Lorenzo performed religious duties, such as meditation and temple cleaning, but she also performed commercial work, including cooking, dishwashing, and serving guests. After leaving the church in 2019, she filed a claim alleging the Zen Center had illegally underpaid her for this commercial work.
The Zen Center argued that the lawsuit should be dismissed under the ministerial exception, a rule that protects churches from lawsuits that interfere with religious doctrine or the hiring of ministers. The Court of Appeal disagreed. The court reasoned that unlike wrongful termination cases, wage-and-hour claims do not force the court to intervene in a church's faith or internal doctrine. Since the Zen Center could not prove that paying staff minimum wage interfered with its religious mission, the court ruled in Lorenzo’s favor, allowing her wage claim to move forward. Lauren 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. She is Co-Chair of the Amicus Committee of the California Employment Lawyers Association, which submitted an amicus brief in favor of Lorenzo’s argument that the ministerial exception did not bar her claim for wage-and-hour violations. If you believe you have a wage-and-hour claim, click here to get in touch with our office.
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 Lauren Teukolsky is set to speak at the 2026 New Employment Law Practitioner Conference on Wage & Hour Basics. The virtual conference will take place on February 5-6, 2026 and is hosted by the California Lawyers Association’s Labor and Employment Law Section.
The conference is designed for new attorneys, professionals transitioning into labor or employment law, and HR practitioners. Attendees will receive practical and foundational guidance to help them confidently navigate the complexities of wage-and-hour rules and the broader field of employment law. Ms. Teukolsky has worked to protect employees’ rights for over two decades and speaks regularly at conferences on employment law. In the past year, Ms. Teukolsky spoke at the CLA Advanced Wage & Hour Conference on the Private Attorneys General Act (“PAGA”); a conference at the Berkeley Law School on sexual harassment; and a LACBA symposium on PAGA. 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 CLA Conference on February 5-6, 2026, click here. If you believe you’ve been treated unlawfully in the workplace and want to get in touch with our office, click here.  Three major federal employee unions, including the American Federation of Government Employees (AFGE), have filed a lawsuit against the Office of Personnel Management (OPM), alleging that a new question on federal job applications creates an impermissible “political loyalty test.” At issue is a prompt now included in many job postings that asks candidates how they would “help advance the president’s executive orders and policy priorities” to identify specific initiatives they would support.
According to the unions, this requirement converts a traditionally merit-based civil service system into an unconstitutional political vetting process. Their complaint alleges that compelling applicants to explain their support for presidential policies infringes on First Amendment rights and chills political expression. The unions also cite data showing the essay prompt has appeared in over 5,800 postings, spanning from policy roles to maintenance and clerical positions. The OPM has defended the prompts as a lawful method to evaluate applicants’ skills and commitment to public service. Director Scott Kupor maintains that responses to the essay are optional and that hiring decisions “cannot consider political or ideological beliefs.” Still, the unions assert that internal guidance effectively makes the question mandatory and that political appointees may review the answers. The lawsuit will likely require the court to determine whether federal hiring standards may include political loyalty tests. For more on the latest developments in employment law, visit our blog here. If you believe you may have been discriminated against in the hiring process, click here to get in touch with our office.  Lauren Teukolsky’s “Wage and Hour Case Notes” were published in the November 2025 edition of the California Labor and Employment Law Review. Her column describes recent decisions from California’s appellate courts that affect wage-and-hour law, including Iloff v. LaPaille, a California Supreme Court case that makes it easier for employees to prove minimum wage violations.
The 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 every other quarter. 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.  A federal court has blocked California’s “captive audience” law, halting Senate Bill 399, which was to take effect on January 1, 2025. The law would have prevented employers from requiring employees to attend workplace meetings on political, religious, or union topics, allowing employees to opt out without fear of retaliation. Supporters argued it protected workers from coercive tactics, while business groups claimed it infringed on employer speech and conflicted with federal labor law.
The California Chamber of Commerce sued to block the law, claiming it encroached on the National Labor Relations Act (NLRA), which grants the National Labor Relations Board (NLRB) authority over private-sector labor relations. The U.S. District Court granted a preliminary injunction, finding S.B. 399 is likely preempted by federal labor law and violates the First Amendment by targeting employer communications based on content. Employers are allowed to hold “captive audience” meetings as litigation on S.B. 399 continues. For more on the latest developments in employment law, visit our blog here. For our previous coverage on S.B. 399, click here. If you believe your employer may have violated workplace laws, click here to get in touch with our office. LAUREN TEUKOLSKY RECEIVES 2025 SERVICE AWARD FROM CALIFORNIA EMPLOYMENT LAWYERS ASSOCIATION10/27/2025  Lauren Teukolsky of Teukolsky Law, APC was recently honored with a 2025 Service Award by the California Employment Lawyers Association (CELA). CELA selected Ms. Teukolsky based on her “leadership and service on numerous CELA Committees and dedication to the rights of working people.”
CELA is a statewide organization of more than 1,300 California attorneys who devote the majority of their practices to representing employees in individual and class action employment cases. CELA works to protect and expand the legal rights of workers through litigation, education, and advocacy. Ms. Teukolsky has more than 20 years of experience litigating employment cases. She has been a CELA member since 2002. She served as Co-Chair of CELA’s Wage & Hour Committee from 2019-2021, and currently serves on the Amicus Committee. 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 learn more about Ms. Teukolsky, click here. If you believe you have been wrongfully terminated, harassed, or suffered from other unlawful workplace practices, click here to get in touch with our office.  California has passed a law banning “stay-or-pay” provisions in employment agreements. Effective January 1, 2026, A.B. 692 prohibits employers from requiring workers to repay training costs or other debts if they leave their jobs.
Stay-or-pay requirements, also known as training repayment agreement provisions, or TRAPs, cause workers to stay with an employer out of fear of repaying thousands of dollars in training costs. Employers use TRAPs to incentivize workers to stay in their jobs. Critics say that stay-or-pay clauses limit job mobility and force employees to work for lower wages. The American Civil Liberties Union has called these contracts “a form of indentured servitude.” TRAPs often exacerbate gender and racial disparities in the workplace because immigrants and women of color disproportionately hold low wage jobs with stay-or-pay provisions. The law, which adds a new section to the California Labor Code, permits employees subject to TRAPs to sue for civil penalties with a minimum of $5,000 per worker. Some narrow exceptions exist for loan repayment assistance program contracts and tuition repayment contracts. Lauren 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 believe you are subject to an unlawful TRAP, click here to get in touch.  On October 8, 2025, Governor Newsom signed the Equal Pay Enforcement Act (SB 642) into law. Effective January 1, 2026, the new law strengthens California’s Equal Pay Act by broadening wage transparency requirements and extending the timeframe for employees to bring claims.
Under SB 642, employers are now required to provide a good faith estimate of expected pay in job postings. Pay ranges may only vary 10% above and below the mean pay for any given position. The law extends the time that employees may file a claim from two to three years. It adopts the continuing violations doctrine, allowing workers to seek back pay for up to six years. Additionally, the law clarifies that the requirement of equal “wages” covers not just monetary pay, but also equity grants like stock and stock options. The law modernizes existing protections by removing binary gender language, protecting all employees regardless of gender identity. SB 642 is an important step toward addressing the racial and gender wage gap. American women lose $1.7 trillion annually because of the wage gap. Black women earn just 64 cents for every dollar earned by a white man. Mariko Yoshihara, Policy Director for the California Employment Lawyers Association, explained that, “one of the biggest barriers to advancing pay equity is that workers often don’t know that they are being paid unfairly until it is too late.” Lauren 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 her about an employment matter, click here.  California is leading the nation with new regulations on the use of artificial intelligence (AI) in employment practices. Starting October 1, 2025, employers must follow antidiscrimination rules when using AI systems to make decisions on hiring, firing, promotion, or performance evaluations. If an AI system demonstrates bias against a protected group, even unintentionally, it may violate state civil right protections. This addresses a growing concern that AI tools used in decision-making may amplify existing inequalities in the workplace.
A wide range of AI tools used by employers are covered by the new regulations, from resume screeners to automated applicant ranking systems. Employers are encouraged to test these tools regularly for biases and document active preventative measures taken to mitigate potential discrimination in their AI tools. These records must be preserved for four years. The bottom line is that employers must explain how employment decisions using AI tools are made with preventative measures in mind. For workers, these regulations provide a legal pathway to relief if they believe AI has been used to discriminate against them. For employers, the regulations create an incentive to conduct frequent bias testing and training as insurance against any lawsuits. Employers can raise evidence of anti-bias testing as an affirmative defense against AI discrimination lawsuits. Courts will have to weigh factors like the quality and timing of an employer’s bias testing, and whether any harmful results were addressed. Additional AI legislation, SB 7, is on Governor Newsom’s desk awaiting signature. The bill could restrict employers from using AI to make personnel decisions without human involvement. California agencies are considering additional AI regulations in housing, education, lending, and health care. Lauren 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 her about an employment matter, click here. California lawmakers have advanced a bill that would allow the state to protect labor relations and unionization efforts traditionally handled by the federal government. The bill comes amid a crisis at the National Labor Relations Board (NLRB), which was left nonfunctional earlier this year. In February 2025, President Donald Trump dismissed a member of the NLRB, leaving the five-member Board without a quorum necessary to conduct business. With the board left paralyzed, the NLRB’s backlog of unaddressed cases continues to grow. States are now beginning to look at alternative ways to protect labor rights.
California Assembly Bill 288 is intended to circumvent the NLRB by significantly expanding the powers of the state’s Public Employment Relations Board (PERB). PERB currently handles only public sector labor disputes. The proposed law would grant PERB authority to hear labor matters affecting private-sector workers if a case brought to the NLRB does not receive a response in six months. Once signed into law, AB 288 allows workers to petition PERB to rule on unfair labor practices, certify a union, order employers to bargain, and impose civil penalties. The law does not create new rights. Instead, it creates a parallel enforcement process in the absence of an NLRB quorum. The bill was sent to Governor Gavin Newsom’s desk and is awaiting his signature. Union sponsors of the bill are urging Governor Newsom to sign it into law. "Under AB 288, when the NLRB is unable or unwilling to act, the state will step in to enforce the law and ensure that workers who want a union actually get a union," said Lorena Gonzalez, President of the California Federation of Labor Unions, AFL-CIO. Lauren 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 her about a labor matter, click here. |
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Teukolsky Law, A Professional Corporation, represents clients throughout California. Ms. Teukolsky is admitted to practice in the State of California, as well as the United States Supreme Court, Ninth Circuit Court of Appeals, Northern District of California and Central District of California. Disclaimer.
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