Posts By: Jason Resnick

California Expense Reimbursement: Best Practices

California Labor Code section 2802 states that employers must indemnify their employees for all necessary expenditures or losses incurred as a direct consequence of their job duties.  It's crucial for employers to understand the guidelines and best practices surrounding this process.  It is recommended that employers establish a clear policy regarding expense report submissions. Employers…

Best Practices: California Meal and Rest Periods

If you are an employer in California, it is important to ensure that you are in compliance with the state's meal and rest laws. Failure to comply with these laws can result in costly penalties and legal action against your company. Here are some key points to keep in mind:  Meal Periods:  Employees who work more than 5 hours in a day must be provided with a 30-minute uninterrupted meal…

California Employers on Edge: Adolph v. Uber Technologies to be Heard on May. 9

[Correction: An earlier version of this post stated that oral argument is scheduled for August 7. That is the date by which the Supreme Court should issue its decision in the case] Oral argument in Adolph v. Uber Technologies is scheduled for May 9, 2023. On that date, the California Supreme Court will hear arguments to determine if someone with an individual PAGA claim in arbitration can…

Navigating Health Benefits During Workers’ Compensation Leave

When an employee is absent due to a workplace injury and receiving workers' compensation benefits, their health insurance is not covered by workers' compensation. However, there are options available to protect an employee's health benefits. If the employee qualifies for the federal Family and Medical Leave Act (FMLA) or state leaves such as the California Family Rights Act (CFRA) or pregnancy…

H-2A Visa Fees to Increase May 30

The U.S Department of State published a Final Rule on March 28th regarding increases to certain nonimmigrant visa application (NIV) processing fees and the Border Crossing Card (BCC) for Mexican citizens. Effective May 30, 2023, H-2A and H-2B visa fees will increase from $190 to $205.  The pending visa fee increase is on top of US Citizenship and Immigration Services’ (USCIS) proposed…

Legal Webinar: How to Build a Reputation for ESG Without “Greenwashing”

As scrutiny intensifies around organizations’ ESG efforts – such environmentally friendly, sustainable growing, and ethical sourcing practices – the risk of litigation, regulatory enforcement, and high-profile media headlines increases. What can be learned from this and how can directors, managers, in-house legal departments, and other stakeholders learn how to build a reputation for ESG…

Courts Apply Viking River with Mixed Results

The U.S. Supreme Court’s decision last June in Viking River Cruises v. Moriana was viewed by many as a victory for employers. The Court allowed individual Labor Code Private Attorneys General Act of 2004 (PAGA) claims to be compelled to arbitration and required the dismissal of non-individual PAGA claims brought on behalf of others.  The case has resulted in a wave of motions in state and…

California Court of Appeal Holds Viking River Does Not Deprive Plaintiffs of Standing to Pursue “Representative” PAGA Claims Even if Compelled to Arbitrate “Individual” PAGA Claims

The California Court of Appeal for the Second Appellate District recently issued a decision that disagreed with the Supreme Court's interpretation of the Private Attorneys General Act of 2004 (“PAGA”) in Viking River Cruises, Inc. v. Moriana. PAGA allows employees to sue their employers for Labor Code violations on behalf of themselves and other current or former employees. Viking River held…

DOL to Host Webinar on New H-2A Wage Rule

The Department of Labor’s Office of Foreign Labor Certification invites interested stakeholders to participate in a webinar that provides an overview of the new Adverse Effect Wage Rate (AEWR) Rule and gives the stakeholder community an opportunity to familiarize itself with the regulatory changes. The webinar will discuss the methodology behind the new AEWR rule and prepare examples of how it…

DOL Publishes FAQ on New H-2A Wage Rule

 The U.S. Department of Labor has published a new Frequently Asked Questions (FAQ) regarding the final rule establishing a new methodology for determining hourly Adverse Effect Wage Rates (AEWRs) for non-range occupations for temporary labor certifications in the H-2A program. Employers who submit an H-2A job order on or after March 30, 2023, will be subject to the new AEWR methodology for…

Industry Files Amicus Brief in PAGA Case Before California Supreme Court

A coalition of industry groups, including Western Growers, has filed an amicus curiae brief in the California Supreme Court in Adolph v. Uber Technologies, a case which will examine the ruling that purportedly provided relief to employers from California Labor Code Private Attorneys General Act PAGA claims in the recent decision from the United States Supreme ...

Industry Files Amicus Brief in PAGA Case Before California Supreme Court

A coalition of industry groups, including Western Growers, has filed an amicus curiae brief in the California Supreme Court in Adolph v. Uber Technologies, a case which will examine the ruling that purportedly provided relief to employers from California Labor Code Private Attorneys General Act PAGA claims in the recent decision from the United States Supreme ...

Webinar AB 2183: What Can Farmers Expect in 2023

Western Growers and Ventura County Agricultural Association invite member owners and Legal/HR representatives to participate in a webinar – AB 2183: What Can Farmers Expect in 2023. The webinar will take place on April 5, 2023 from 10 am – 12:00 pm PDT and will feature Rob Roy, President/General Counsel of Ventura County Agricultural Association and Jason Resnick, Senior Vice President and…

DOL Announces New H-2A Wage Rule

The U.S. Department of Labor announced it will publish a final rule to amend the Adverse Effect Wage Rates for the H-2A program. The final rule, published on Feb. 28 in the Federal Register, says the department will calculate the H-2A wage rates for field workers based on USDA’s Farm Labor Survey of farmworker wages. However, H-2A wage rates for some occupations, such as truck drivers…

CA Labor Commissioner Issues Guidance on New Pay Transparency Law Requirements

California Labor Commissioner Lilia García-Brower has issued an open letter reminding employers of their obligations to comply with the State’s new pay transparency requirements under the California Equal Pay Act. (Labor Code. Sections 423.3 and 1197.5)  Employers with 15 or more employees must include the pay scale for a position in any job posting, and if that employer engages a third…

Save the Date: 2023 Employment Law Update Webinar – March 8, 2023

Please join us for a webinar in which Western Growers attorneys will provide a comprehensive review of the new California and Federal employment laws and cases that will impact employers in 2023 and beyond. Jason Resnick, Sr. Vice President & General Counsel, and Teresa McQueen, Corporate Counsel, will be conducting a content-packed webinar to update organizations about the latest changes…

Farm Labor Survey Shows H-2A Wage Increase for 2023

Last week, the U.S. Department of Agriculture released data from its annual farm wages report. USDA’s Farm Labor Survey is used to calculate the 2023 Adverse Effect Wage Rate (AEWR), which determines the minimum wages for H-2A workers in each state. California employers can expect to see the AEWR increase from $17.51 per hour to $18.65 ...

Upcoming H-2A Regulations Listening Session for Employers

The U.S. Department of Labor will conduct a virtual listening session for employers and their representatives to gather input about possible changes to the regulations governing the H-2A visa program for temporary agricultural employment of foreign workers. DOL’s stated goals are to listen, engage the public, and hear from many voices who could be impacted ...

U.S. Department of Labor publishes Additional H-2A FAQs

The U.S. Department of Labor has published a third set of FAQs regarding the 2022 H-2A Final Rule. According to DOL’s press statement the Office of Foreign Labor Certification (OFLC) has issued a set of Frequently Asked Questions (FAQs), Round 3 – Job Offers, Assurances, and Obligations – Wages, associated with the publication of the ...

USCIS Proposes Massive Hike in H-2A Fees

The US Citizenship and Immigration Services (USCIS) has proposed a massive hike in immigration petition fees, including fees to petition for H-2A visas for temporary and seasonal agricultural workers. Under the proposed ruled, published by USCIS on Jan. 4, 2023, the fee for an H-2A Petition for unnamed beneficiaries would increase from the current $460 ...