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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision
Mar 02, 2016

Zaldivar v. JMJ Caterers, Inc.

The plaintiff, Orbin Zaldivar, a former dishwasher and food preparer, filed a wage and hour action against JMJ Caterers, Inc. d/b/a The Metropolitan, Michael Giamalvo, and Janender Narang, alleging violations of the FLSA and NYLL for unpaid overtime. Zaldivar claims the defendants used a 'two punch card' system to avoid paying overtime by recording regular hours on one card and overtime hours (paid in cash at the regular rate) on a second card. He moved for conditional certification of a collective action, asserting that other kitchen staff, servers, and busboys were subjected to the same unlawful policy. Despite defendants' opposition challenging the factual allegations and the scope of the class, the Court granted the motion for conditional certification, finding that the plaintiff made a modest factual showing of a common policy that violated the law and that other employees were similarly situated. The Court conditionally certified a class of all servers, busboys, and kitchen workers employed by The Metropolitan from December 28, 2012, to the present.

Overtime payFLSANYLLwage and hourcollective actionconditional certificationpunch card systemunpaid wagessimilarly situated employeesemployment law
References
71
Case No. ADJ8838013
Regular
Dec 01, 2016

AARON CARRILLO vs. LLG CORPORATION, DBA FRESCO II, EMPLOYERS COMPENSATION INSURANCE COMPANY

This case involves a busboy who injured himself in a car accident after consuming alcohol on his employer's premises after his shift. The applicant sought workers' compensation, arguing that his injuries arose out of and in the course of employment, with alcohol use being a customary incident. The Board denied reconsideration, affirming the WCJ's finding that the applicant did not sustain an industrial injury. The applicant's presence and drinking were deemed personal socializing, not an employer-sanctioned or expected activity, thus not meeting the AOE/COE standard.

AOE/COEcustomary incident of employmentpost-shift intoxicationreasonable expectancy of employmentintoxication defenseproximate and substantial causeMcCarty v. Workers' Comp. Appeals Bd.social patroncredibility determinationLabor Code section 3600
References
9
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