Respondent city sued appellant employee for breach of contract after the employee failed to reimburse the city, as agreed, for the costs of training him to become a police officer. The employee filed a cross-complaint against the city and respondent police chief. The employee challenged summary judgments entered by the Superior Court of Alameda County, California, for the city on its complaint and for respondents on the cross-complaint.
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Overview
The trial court denied the employee’s summary judgment motion. The employee’s cross-complaint alleged that the agreement to repay the city for training costs violated the federal Fair Labor Standards Act (FLSA), 29 U.S.C. §§ 201-219, and various state laws. The court held that the employee failed to establish that the agreement to reimburse the city for training costs violated the FLSA. The city was permitted to seek reimbursement from police officers who gained the benefit of its training program at its police academy but did not stay with the police department long enough for the city to benefit from that training. The city’s withholding of the employee’s final paycheck to cover his debt did violate the FLSA. The filing of the employee’s cross-complaint against the police chief more than three years after the withholding of his checks was untimely. The court was not persuaded that the city established that any violation of the FLSA was not willful. The three-year statute of limitations did not apply to the employee’s statutory causes of action against the city. There was a triable issue as to whether the seizure of the employee’s final paycheck violated Lab. Code, §§ 221 and 223.
Outcome
The court affirmed the summary judgments for the city on its complaint and for the police chief on the cross-complaint, as well as the denial of the employee’s summary judgment motion. The court reversed the summary judgment as to the claims of violations of the FLSA and of Lab. Code, §§ 221, 223, for seizure of the employee’s final paycheck in his cross-complaint against the city and remanded the case to the trial court for further proceedings.
