In April 2020, when the Social Security Administration (SSA) announced it was discontinuing its practice of issuing Employer Correction Request Notices (e.g., “no match” letters), many employers in key industries such as Agriculture were relieved. However, relief from the administrative burden and perceived risk such notice created quickly gave way to confusion about ongoing verification responsibilities.

In a recent ruling the Ninth Circuit (covering California and Arizona) upheld a motion to compel arbitration by a non-signatory to an arbitration agreement (Franklin v. Community Regional Medical Center, FKA, No. 19-17570 (9th Cir. 2021)). Franklin, a contract nurse employed by a staffing agency and assigned to Community Regional Medical Center (CRMC), filed a class and collective action against CRMC for state and federal wage and hour violations.

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