California Supreme Court Watch

#23-2 Ruelas v. County of Alameda, S277120. (9th Cir. No. 21-16528; 51 F.4th 1187; Northern District of California; D.C. No. 4:19-cv-07637-JST.) Request under California Rules of Court, rule 8.548, that this court decide a question of California law presented in a matter pending in the United States Court of Appeals for the Ninth Circuit. The question presented is: “Do non-convicted incarcerated individuals performing services in county jails for a for-profit company to supply meals within the county jails and related custody facilities have a claim for minimum wages and overtime under Section 1194 of the California Labor Code in the absence of any local ordinance prescribing or prohibiting the payment of wages for these individuals?”

Request for certification granted: 1/11/2023

Case fully briefed: 5/02/2023

Cause argued and submitted: 2/06/2024

Opinion filed: 4/22/2024

See the Order Certifying Question to the Supreme Court of California.

See the Oral Argument.

See the California Supreme Court Opinion.  (Ruelas v. County of Alameda (2024) 15 Cal.5th 968.)

“Inmates at the Santa Rita Jail in Alameda County work in the kitchen preparing meals for the county jail population and staff under an agreement between the county and a private contractor. They are not paid for their labor. A group of nonconvicted individuals who were performing this labor while detained at the jail sued the county and the private contractor in federal court for failing to pay minimum wage and overtime. The United States Court of Appeals for the Ninth Circuit has asked us to decide whether nonconvicted incarcerated individuals working in a county jail for a private company have a claim for minimum wage and overtime under California law. We conclude the answer is no.

…

Under the law as it currently stands … we conclude that nonconvicted incarcerated individuals performing services in county jails for a for-profit company to supply meals within the county jails and related custody facilities do not have a claim for minimum wages and overtime under Section 1194 of the California Labor Code, even in the absence of a local ordinance prescribing or prohibiting the payment of wages for these individuals.”

Justice Evans authored the opinion of the Court, in which Chief Justice Guerrero and Justices Corrigan, Liu, Kruger, Groban, and Jenkins concurred.