California appellate court reverses ruling for ex-ranch worker who alleged years of unpaid work

By Elizabeth Alt | Mar 2, 2018

SAN FRANCISCO -- A former ranch worker has won his appeal against his former employer for unpaid wages and overtime compensation.

SAN FRANCISCO -- A former ranch worker has won his appeal against his former employer for unpaid wages and overtime compensation. 

Michael Steffen said he worked for free because the deceased owner said he would be given the ranch’s home. The trial court originally ruled in favor of the defendants who said the man passed the statute of limitations to claim unpaid wages.

In the ruling, the California First District Court of Appeal said the trial court ruling was flawed, stating, “All three arguments are improperly focused on the terms of the 2008 agreement and Triple Z’s repeated premise that ‘this is [only] a promise to make a will case.’  Triple Z and the trial court apparently fail to recognize the dual nature of the claims at issue and that Steffen’s statutory wage rights are unwaivable.” Justice Terence Bruiniers wrote the court opinion, with Justice Mark Simons and Justice Henry Needham concurring. 

Steffen worked for Triple Z Ranch LLC from 2002 until 2012, when the original owner, Armand Zimmerlin, passed away. In 2008, Steffen said he and Zimmerlin made an oral agreement that Steffen would be working for Zimmerlin’s home and cottage without payment in exchange for being given the cottage at some point in the future. Steffen said that he took care of Zimmerlin when he fell ill, and that before his boss died, he told Steffen that he’d left him “quite a nest egg”. 

Although Zimmerlin lived on the property, he transferred ownership on the title of the house and cottage to Triple Z in 2001, which Steffen says was for tax purposes. When Zimmerlin died, Steffen continued to work under the new owners, Katherine Byrne, Susan Byrne, and Charles Jones. 

Steffen alleges Jones knew of the agreement and acknowledged in a discussion that he was aware Steffen was working in exchange for “the cabin and 20 acres. However, in 2013, when Steffen turned in his notice after finding another job, Jones said claimed he didn’t have any knowledge of such an agreement and Steffen was fired in 2014.

Steffen filed suit against Triple Z and its owners, alleging labor code violations as well as promissory estoppel, unfair business practices, fraud, breach of contract, quiet title, and adverse possession causes of action. 

The owners objected and said the labor code violations did not apply to Triple Z because Steffen only named Zimmerlin as his employer in his complaint, not Triple Z, and that Steffen’s wage claims were barred by a two-year statue of limitations because they were an oral agreement. Steffen decided not to pursue charges against Zimmerlin’s estate in his second amended complaint.

The trial court ruled in favor of Triple Z, stating Steffen “cannot allege in a timely claim that he is owed wages from an employer whose identity he did not know until after he filed his complaint.” 

Steffen appealed the ruling.

Reversing the trial court ruling, Bruiniers stated, “[The] defendants failed and refused to compensate Steffen in an amount to be proven at trial for the overtime hours he worked at the required overtime rate, and in many instances did not compensate [him] for any of the hours worked at all.” Bruiniers said Steffen’s claims were timely and fell under the statute of limitations. 

Triple Z argued that Steffen was trying to make a statutory wage claim from the oral agreement for his work in exchange for the cottage.  

Bruiniers stated, “We are wholly unpersuaded by Triple Z’s attempt to characterize Steffen’s SAC as seeking specific performance of the 2008 agreement.” He added e “the trial court’s ruling cannot be upheld on the ground Steffen failed to allege he was due “wages” under the labor code.”

The appellate court ruled that Steffen is entitled to costs from the appeal. 

California Court of Appeal, First District, case Number  A149486

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