A United Airlines mechanic can proceed with his Private Attorneys General Act (PAGA) lawsuit seeking civil penalties for alleged violations of California’s meal break requirements, a California appeals court held.
The trial court said the action was pre-empted by the federal Railway Labor Act (RLA) because the court would have to interpret the parties’ collective bargaining agreement (CBA). But the appeals court disagreed.
Background
The plaintiff was employed as a mechanic at Los Angeles International Airport. Mechanics are subdivided into line technicians or base technicians, among other categories. Line technicians, such as the plaintiff, perform maintenance on aircraft that are currently in service and arriving or departing from a United station. Their duties include responding to mechanical concerns raised by the aircraft’s flight crew and ensuring equipment is in working order before the aircraft takes off.
The terms and conditions of the plaintiff’s employment are governed by a CBA that was negotiated and approved under the RLA.
Under the agreement, a normal workday is eight hours, with a 30-minute unpaid meal break and two 10-minute rest breaks. If a mechanic works two or more hours of overtime, the employee is entitled to an additional 30-minute paid meal period.
The California Labor Code prohibits an employer from requiring employees to work during meal and rest periods that are mandated under an applicable wage order from the Industrial Welfare Commission. The wage order that covers the plaintiff’s role requires an employer to provide a second meal period of at least 30 minutes for any employee working more than 10 hours a day.
The employee filed a representative action under PAGA raising only one claim—that United is violating California’s meal break law by failing to provide a second meal break to mechanics who work shifts of more than 10 hours.
The trial court dismissed the action before trial, concluding that the lawsuit was pre-empted by the RLA…