Aaron Buckley Writes Bender’s California Labor & Employment Bulletin Article About California Court of Appeals Decision Regarding Employer’s Section 998 Offer in Wage Dispute

Article

Aaron Buckley, national vice chair of the Quarles & Brady Labor & Employment Practice Group, wrote an article for Bender’s California Labor & Employment Bulletin about a California Court of Appeals decision related to a wage dispute where a Section 998 offer was made by an employer. Section 998 encourages parties to settle before trial. The article outlines the outcome of the case and how it can impact similar cases in the future.

An excerpt:

Prior to trial Chavez and Isas accepted settlement offers under Code of Civil Procedure section 998, but Zarate did not accept either of two section 998 offers made to him: the first in the amount of $38,750 plus reasonable attorney fees and costs, and the second in the amount of $60,000 plus reasonable attorney fees and costs. 10

Reviewing the legislative histories of Sections 1194 and 218.5, the appellate court determined they evidenced a legislative policy in favor of allowing employees to bring wage suits, and concluded that policy “would be undermined by permitting Section 998 to require an employee to pay costs in unsuccessful.”21 The court also notes that Section 1194 and 218.5 were amended in 1991 and 2013, respectfully, after the 1987 enactment of Section 998 and, therefore, to the extent they conflict with Section 998, they supersede it.22

Resources

Originally published in Bender’s California Labor & Employment Bulletin, February 1, 2025 (Subscription required)

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