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Court Clarifies When a PAGA Settlement Resolves Multiple Lawsuits

In a newly published decision, the California Court of Appeal (Second District, Division Eight) affirmed the dismissal of a representative PAGA action on claim preclusion grounds, holding that a prior global PAGA settlement barred a subsequent plaintiff’s overlapping claims – even though the settling plaintiff had filed an amended complaint only 35 days after submitting an amended Labor & Workforce Development Agency (LWDA) notice for newly added claims and defendants.

In this case Lauren Brown, a former Dave & Buster’s employee, filed a standalone PAGA suit in June 2019 alleging meal and rest-break violations, off-the-clock work, inaccurate wage statements, and unpaid vacation wages under Labor Code § 227.3.

At that time, at least four other PAGA actions were already pending against the same Dave & Buster’s entities. One of those earlier actions – Andrade v. Dave & Buster’s Management Corporation, Inc. (San Diego Superior Court) -ultimately achieved a court-approved global settlement in November 2022 that expressly released all of the claims Brown was asserting, including the § 227.3 vacation claim, and covered all three Dave & Buster’s entities Brown had sued.

Dave & Buster’s successfully moved for judgment on the pleadings in Brown’s case, contending that the Andrade settlement constituted a final judgment on the merits of the same cause of action between parties in privity, thereby precluding Brown’s suit. The trial court agreed and dismissed the action with prejudice.

The Court of Appeal affirmed the dismissal in the published case of Brown v. Dave & Buster’s of California, Inc. -B339729 (November 2025).

On appeal, Brown conceded that the Andrade settlement precluded her non-vacation claims but argued that (1) she retained standing to pursue post-settlement violations (a contention the Court of Appeal swiftly rejected, noting her employment ended in 2018), and (2) Andrade’s failure to wait the full 65 days after her amended LWDA notice meant Andrade was never “deputized” to pursue or settle the newly added vacation-pay claim and additional entities, relying heavily on LaCour v. Marshalls of California, LLC (2023) 94 Cal.App.5th 1172.

The Court of Appeal distinguished LaCour, in which the prior settling plaintiff had never provided LWDA notice of the additional claims at all. Here, Andrade did provide an amended notice that specifically identified the § 227.3 claim and the additional defendants. The court held that the statutory 65-day waiting period does not explicitly apply to amended notices, and even if it did, Andrade substantially complied with PAGA’s administrative exhaustion requirement by giving the LWDA actual notice and an opportunity to act. The LWDA’s subsequent acceptance of the settlement (without objection) rendered the premature filing a harmless technical defect.

Citing federal district court authority and the longstanding doctrine of substantial compliance (historically applied to Government Claims Act notices), the panel concluded that invalidating the settlement on this ground would improperly allow later PAGA plaintiffs to collaterally attack prior approved settlements – an outcome the Supreme Court expressly rejected in Turrieta v. Lyft, Inc. (2024) 16 Cal.5th 664.

Accordingly, the Andrade settlement fully released Brown’s claims against all defendants, satisfying every element of claim preclusion. The judgment dismissing Brown’s action was affirmed, with costs awarded to Dave & Buster’s.

The decision reinforces the finality of approved PAGA settlements and signals that minor procedural deviations in administrative exhaustion will not undermine claim preclusion when the LWDA received actual notice and declined to intervene.

CalChamber Reports 2024 PAGA Reforms are Successful

The Private Attorneys General Act (PAGA), enacted in California over a decade ago, was designed to empower employees to act as “private attorneys general” by suing employers on behalf of the state for alleged Labor Code violations. While intended to bolster worker protections, PAGA evolved into a litigation powerhouse, often criticized for spawning a flood of expansive, costly lawsuits that burdened businesses with unpredictable penalties and discovery demands, sometimes reaching into the millions for minor infractions.

In a pivotal shift, California lawmakers passed comprehensive PAGA reforms in 2024, which took effect about 18 months ago. These changes were no small tweak; they fundamentally recalibrated the scales of justice. Key provisions include:

– – A Strict One-Year Limitations Period: Plaintiffs must now prove they personally suffered violations within the year leading up to filing, curbing the “ancient history” claims that once ballooned cases.
– – Judicial Tools for Manageability: Courts gained explicit authority to narrow claim scopes, limit evidence, and dismiss unwieldy allegations, preventing trials from devolving into fishing expeditions.
– – Penalty Reallocations and Standing Rules: Penalties are now split more equitably – 35% to aggrieved employees (up from 25%) and 65% to the state – while stricter standing requirements weed out opportunistic suits.

These reforms were a direct response to years of advocacy from business groups like the California Chamber of Commerce (CalChamber), who argued that the old system was “broken” and disproportionately harmed employers without meaningfully aiding workers.

How are they working? A new statement just posted by the CalChamber does not mince words on the broader ripple effects: Litigation volumes are down, compliance is up, and the entire ecosystem is healthier. They quote recent employer defense industry reports as evidence that these reforms are “confirming the positive impact on the system for both parties,” with early data suggesting a 20-30% reduction in filed PAGA actions since implementation.

For employers, it’s a breath of fresh air – less fear of rogue suits, more room to innovate and hire. For California, it’s proof that targeted tweaks can restore sanity to a system teetering on the edge.

Key early successes reported by the employer defense industry:

– – Employers Doubling Down on Compliance Efforts. Employers have ramped up their compliance efforts, conducting audits more frequently while training managers and updating policies proactively.
– – Narrower Standing Reduces Frivolous Lawsuits. Employers and defense lawyers report they are now routinely knocking out claims early by proving the plaintiff didn’t experience certain violations, dramatically shrinking exposure. Claims are resolved faster and for less money because legal disputes are narrower and more manageable.
– – More Money & Faster Resolution for Employees. PAGA reforms increased the employee share of penalties from 25% to 35%, with the state receiving 65%. The early resolution process through the state’s Labor and Workforce Development Agency (LWDA) also limits the need for extended and costly litigation.
– – Reduced Penalties for Employers. Reduced penalties now balance fairness with enforcement. Defense firms report significantly reduced penalties on employers because of the PAGA reforms.
– – One-Year Limitations Period. PAGA reforms clarified standing law that a plaintiff must have experienced a violation within the past year to bring a claim.
– – Ability to Limit the Scope of Claims and Evidence to Ensure Manageability. Courts now have explicit authority to limit the evidence to be presented at trial or otherwise limit the scope of a PAGA claim to ensure cases remain manageable for trial.

November 17, 2025 – News Podcast


Rene Thomas Folse, JD, Ph.D. is the host for this edition which reports on the following news stories:IMR Required Despite No Substantive Change in Medical Condition. City & County of San Francisco Prevails in Disabled Retiree FEHA Claim. High Level California Political Figures Indicted for Fraud. Top 10 OSHA Violations Topic at NSC Safety Congress & Expo. Monterey Grower to Pay $126K For Workers Pesticide Exposure. L.A. Fire Survivors Call for Insurance Commissioner Resignation. New App Makes ER an Unnecessary Step for Orthopedic Injury. Novartis Opens New Manufacturing Facility in Carlsbad.

Honda Dealership Prevails in PAGA Wage Hour Dispute

Gonzalez v. Downtown LA Motors, LP (2013) 215 Cal.App.4th 36 is a landmark 2013 California Court of Appeal decision that clarified minimum wage obligations for employees compensated on a piece-rate basis. Drawing heavily on Armenta v. Osmose, Inc. (2005) 135 Cal.App.4th 314 – which prohibited averaging for hourly employees – the Gonzalez court extended the principle to piece-rate systems. Piece-rate compensation rewards only productive tasks (the “pieces” or “flag hours”), so time spent on non-piece-rate activities (including waiting time under the employer’s control) must be separately compensated at no less than the minimum wage. Averaging effectively “borrows” from productive-time earnings to cover non-productive hours, which California law forbids because it undermines the statutory guarantee of minimum pay for all hours worked.

Following Gonzalez v. Downtown LA Motors, LP (2013) 215 Cal.App.4th 36, the dealership (operating as First Honda Simi Valley) replaced its pure piece-rate (“flag hour”) system in December 2014 with an hourly compensation that paid technicians double the applicable minimum wage for every hour recorded on the biometric time clock (including unproductive time and rest periods), with an additional “flag bonus” paid only when the technician’s flag-hour earnings exceeded the guaranteed hourly pay. The plan explicitly labeled the excess amount as a “bonus” and described as compensation for performance “above and beyond a median, expected level.”

“Flag hours” (also called “book hours,” “flat-rate hours,” or “warranty time”) are the predetermined, fixed amount of time that a manufacturer or industry standard assigns to a specific repair or maintenance task, regardless of how long the task actually takes the technician to perform. These flag hours are intended to represent the amount of time a reasonably skilled technician, using proper tools and working at a normal pace, should need to complete the job. For example, the manufacturer may assign 3.2 flag hours to replace a timing belt. If the technician finishes in 2 hours → they still “flag” (earn credit for) 3.2 hours. If the technician takes 5 hours → they still only flag 3.2 hours.

Plaintiffs Gustavo Mora and Mohammad Hanif, former service technicians, filed a lawsuit in 2018 alleging 7 causes of action for wage theft violations, and the case was later amended to include a PAGA cause of action on behalf of plaintiffs and “other employees of” First Honda. Plaintiffs contended that First Honda Simi Valley still violated California’s “no borrowing rule” because unproductive time generated no flag hours, and the dealership was therefore allegedly using potential bonus money to satisfy minimum-wage obligations.

The trial court initially ordered the parties to arbitrate the case pursuant to the parties’ stipulation, but subsequently withdrew the matter from arbitration at appellants’ request, after First Honda failed to timely pay its arbitration fees. After a bench trial, the trial court upheld the dealership’s post-Gonzalez hourly-plus-bonus compensation plan for service technicians and rejected both individual and PAGA claims.

The Second District Court of Appeal (Division Six) affirmed the judgment in favor of the Honda dealership in the published case of Mora v. C.E. Enterprises, Inc. – No. B337830 (November 2025).

The Court of Appeal rejected plaintiffs characterization, holding that the plan complied with California law because technicians were always paid at least double minimum wage for all hours worked, with any flag bonus paid on top as true incentive pay rather than as part of the base rate. The court distinguished Gonzalez, noting that the dealership never averaged or borrowed from productivity pay to meet the minimum-wage floor; the hourly guarantee stood alone and was always satisfied independently.

The court also held that the plan did not violate Labor Code section 226.2. Even assuming the flag bonus constituted piece-rate compensation, the dealership qualified for the safe-harbor provision of section 226.2, subdivision (a)(7) because it expressly paid “an hourly rate of at least the applicable minimum wage for all hours worked” in addition to any flag-hour bonus.

Finally, the court affirmed the trial court judgment against plaintiffs’ PAGA claim. Plaintiffs failed to exhaust administrative remedies as to alleged violations affecting sales and lube employees (the PAGA notice covered only service technicians), and their trial presentation – consisting largely of a law clerk’s assertion that thousands of pay records contained “deficiencies” without concrete examples or calculations – was insufficient to carry their burden of proof.

Worker Misclassification Rules Under Public Works Contracts Clarified

Under the Prevailing Wage Law, Labor Code sections 1720 through 1861, workers employed under a public works contract must generally be paid “prevailing wages.” The prevailing wage is set by the Director of Industrial Relations (Director) and depends on worker classification and location. The Director also creates worker classifications, determining the scope of work for each.Contractors on public works projects must pay workers the prevailing wage under the proper job classification.

Anton’s Services, a subcontractor performing clearing, grubbing, demolition, and incidental tree work on two City of San Diego public works projects (the 2017 Torrey Pines Road slope restoration and sidewalk project and the 2018 Voltaire Street bridge renovation project), classified its workers under the “Tree Maintenance (Laborer)” prevailing wage classification.

The California Division of Labor Standards Enforcement (DLSE) determined that the work actually performed – clearing and grubbing slopes, removing vegetation and roots in preparation for soil-nail wall and sidewalk construction, and trimming/stabilizing a Torrey pine tree to permit continuation of slope work – was construction work expressly excluded from the Tree Maintenance classification and instead fell within the broader “Laborer (Engineering Construction)” (Group 2 or equivalent) classification, which carries significantly higher wage rates.

After investigation, the DLSE issued assessments totaling $47,280.18 ($36,626.30 for Torrey Pines Road and $10,653.88 for Voltaire Street), comprising unpaid prevailing wages, apprenticeship training fund contributions, section 1775 penalties at $120 per violation (found justified due to willful violations and absence of good-faith mistake), and section 1777.7 apprenticeship penalties.

Following an unsuccessful administrative review on stipulated facts before the Director of Industrial Relations, Anton’s sought writ relief under Code of Civil Procedure section 1094.5. The superior court (Hon. Wendy M. Behan) denied the petition.

On appeal, Anton’s challenged the findings of worker misclassification, the imposition and amount of section 1775 penalties, liability for liquidated damages under section 1742.1, and the apprenticeship violations and related penalties.

The Court of Appeal rejected each contention and affirmed the trial court in the published case of Anton’s Services v. Hagen -D084833 (November 2025).

Substantial evidence supported the Director’s finding that the work was construction or incidental to construction and therefore outside the Tree Maintenance classification, which explicitly excludes “any work of any employee performing construction or landscape construction work (including work incidental to construction…).” Tree trimming performed to enable continuation of soil-nail wall and sidewalk construction was incidental to the public works project, not separate non-prevailing-wage tree maintenance.

The section 1775 penalties at $120 per violation were not an abuse of discretion; Anton’s failed to meet its burden to show good faith mistake or prompt voluntary correction, and the violations were properly deemed willful. Liquidated damages under Labor Code § 1742.1 were correctly imposed because Anton’s neither paid the unpaid wages nor deposited the full amount of the assessments into escrow with the Department of Industrial Relations within 60 days of service.

Apprenticeship violations on the Torrey Pines Road Project were established: Anton’s failed to submit DAS 140/142 contract award information to the applicable apprenticeship committee prior to commencement of work and failed to request dispatch of apprentices, violating Labor Code § 1777.5 and title 8, California Code of Regulations, section 230.1(a). The resulting section 1777.7 penalties were upheld.

CVS Pharmacy Inc.Resolves False Claim Act for $18.3M

CVS Pharmacy Inc. has agreed to pay a total of $18,282,280 to the United States and the State of California to resolve allegations that the company violated the Federal False Claims Act and the California False Claims Act when it knowingly submitted claims for reimbursement for certain prescribed medications to California’s Medi-Cal program that were not supported by applicable diagnosis and documentation requirements, U.S. Attorney Eric Grant announced today.

CVS is among the largest pharmacy chains in the United States, with more than 9,000 locations nationwide and more than 1,000 stores in California. CVS submits reimbursement claims for medications dispensed to beneficiaries of the Medi-Cal program – California’s Medicaid health care program administered by the California Department of Health Care Services (DHCS). Medi-Cal relies on both federal and state funding to provide health care to millions of Californians, including those with low incomes and disabilities.

Medi-Cal utilizes a “formulary” list that designates restrictions for certain listed drugs, including restrictions pertaining to diagnoses and required documentation that must be confirmed by the pharmacy before the drug can be prescribed. Drugs listed on the Medi-Cal formulary are commonly referred to as “Code 1” drugs. Medi-Cal will reimburse certain Code 1 drugs only for approved diagnoses, taking into account criteria such as the drug’s safety, efficacy, misuse potential, and cost. Pharmacies such as CVS serve the critical gatekeeping function of confirming and certifying that these Code 1 drugs are dispensed for the approved diagnoses. CVS may bill for drugs prescribed outside of the approved diagnoses, but it must submit a request to DHCS that includes a justification for the nonapproved use.

Today’s settlement resolves allegations that CVS failed to confirm and document the requisite diagnoses, and in some instances dispensed drugs for nonapproved diagnoses, then knowingly billed Medi-Cal for those prescriptions.

“This settlement demonstrates our commitment to protect the integrity of this critically important federal-state program serving low-income and disabled citizens of this District,” said U.S. Attorney Grant. “My office will continue working to ensure that pharmacies comply with important program regulations like those at issue here.”

“Proper billing of federal health care programs is essential and underpins the reliability of our health care system. Oversight is key to ensuring that compliance failures are remedied,” said Acting Chief Counsel to the Inspector General Susan Gillin of the Department of Health and Human Services Office of Inspector General (HHS-OIG). “Although CVS entered into a health care fraud settlement with the United States, CVS did not agree to compliance-related oversight with HHS-OIG through a corporate integrity agreement.”

This settlement includes the resolution of claims brought by a former CVS pharmacist under the qui tam or whistleblower provisions of the Federal False Claims Act. Under those provisions, a private party can file an action on behalf of the United States and receive a portion of any recovery from that action. The qui tam case is captioned: U.S., et al. ex rel. Zimniski v. CVS Health Corporation, no. 2:19-cv-1118 (E.D. Cal.). As part of the settlement announced today, the whistleblower will receive approximately $3.3 million of the recovery proceeds.

This settlement is the result of a joint effort by the United States Attorney’s Office for the Eastern District of California and California’s Department of Medicaid Fraud and Elder Abuse, with assistance from HHS OIG and the Federal Bureau of Investigation. Assistant U.S. Attorney Catherine Swann handled the case for the U.S. Attorney’s Office.

The claims resolved by this settlement are allegations only, and there has been no determination of liability.

Wells Fargo Pays $85M to Settle Fake Diversity Job Interview Class Action

A New York Times investigative article titled “At Wells Fargo, a Quest to Increase Diversity Leads to Fake Job Interviews” published on May 19, 2022, exposed a troubling practice within Wells Fargo’s wealth management division where managers conducted sham interviews with diverse candidates (primarily women and people of color) solely to meet internal diversity quotas and satisfy regulatory scrutiny, rather than to offer real job opportunities. These interviews were described as performative exercises to document “diversity efforts” on paper, even though the positions were often already filled or promised to non-diverse candidates.

According to the article seven current and former employees reported being instructed by bosses or HR to interview diverse candidates for roles that were pre-decided. The interviews were not intended to lead to hires but to create records showing compliance with diversity goals. Five other employees were aware of or assisted in arranging such interviews.

This stemmed from Wells Fargo’s aggressive push to increase diversity in its workforce, particularly in wealth management, following past scandals. The focus shifted to superficial metrics, such as the number of diverse candidates interviewed, to prepare for audits by regulators like the Federal Reserve.

Wells Fargo’s leadership, including CEO Charles Scharf, had publicly touted the bank’s diversity commitments. For instance, Scharf emphasized in 2021 that diversity was a priority, but the article highlighted a disconnect between these statements and on-the-ground practices.

Joe Bruno, a former managing director in wealth management who was fired in August 2021 after raising concerns, called the practice “inappropriate, morally wrong, ethically wrong.” He alleged his termination was retaliation for his complaints, though Wells Fargo claimed it was for unrelated reasons.

The bank denied tolerating such behavior, with spokeswoman Raschelle Burton stating in an email that Wells Fargo “expects all employees to follow our hiring policies and guidelines” and holds violators accountable. However, the article suggested the practice was widespread and informally encouraged. In a follow-up development noted in the article’s update, Wells Fargo announced a temporary “pause” on the policy that enabled these fake interviews, signaling some acknowledgment of the issue.

This exposé contributed directly to the shareholder lawsuit against Wells Fargo, as it revealed how misleading public statements about diversity progress allegedly inflated the stock price, leading to losses when the truth emerged.

The lead plaintiff was SEB Investment Management AB (a Swedish institutional investor). The case began with individual investor Khosrow Ardalan filing in June 2022, but after consolidation, SEB was appointed lead plaintiff. Ultimately the case became a certified class action representing all persons/entities who purchased or acquired Wells Fargo common stock between February 24, 2021, and June 9, 2022 (inclusive) and suffered damages.

The parties reached an $85,000,000 all-cash settlement in September 2025 (announced to the court on September 25, 2025), with no admission of wrongdoing by Wells Fargo. The federal court granted preliminary approval on November 13, 2025, finding the settlement fair, reasonable, and adequate under Rule 23(e). Final fairness hearing will be scheduled later (motion for final approval due April 28, 2026).

Fraudulent Claimants Paid Millions to Indicted VA Claims Examiner

Daniel Rikkels of Chula Vista was indicted by a federal grand jury on charges that he helped veterans fraudulently obtain disability benefits from the Department of Veterans Affairs (VA) while he was a department employee responsible for reviewing and approving disability claims.

In 2021, his annual VA salary was $106,963. This salary was 20 percent higher than the average and 45 percent higher than the median salary in the VA. He held two jobs from 2016 to 2024. From 2016 to 2023 Daniel Rikkels J held job of Veterans Claims Examining.

According to the 33-count indictment, since 2020, Rikkels knowingly and intentionally instructed veterans to provide false, exaggerated, and misleading claims of service-related injuries to support their disability claims. Rikkels also instructed veterans to alter documents submitted during the claims process.

Through these false claims, the indictment said, veterans fraudulently obtained millions of dollars in VA disability payments and backpay, and Rikkels received millions of dollars in payments from the veterans in return for his work on their behalf.

Until June of 2025 when he retired, Rikkels was employed by the Department of Veterans Affairs and was responsible for reviewing and approving VA disability claims from veterans. During this time-period he negotiated with veterans for assistance in their VA claims and demanded payment from them, all while he was taking official action on their claims in violation of government ethics laws.

The indictment also alleges that Rikkels frequently requested that veterans who lived in the local area meet him to make payments in cash to minimize what he would have to pay in taxes. According to court records, the investigation revealed that during just a three-month period between February and May of 2025, Rikkels met with at least four local veterans and received a total of $57,000 in cash payments from them. On November 13, 2025, agents searched Rikkels, his vehicle, and residence and seized a total of over $280,000 in cash.

Rikkels plead not guilty on November 14, and was released on $750,000 bond secured by Trust Deed.

“The Department of Veterans Affairs and the VA disability system serve a crucial role in providing support and care to those who have served and sacrificed in defense of our country,” said U.S. Attorney Adam Gordon. “We will zealously safeguard the integrity of the VA disability program and will investigate and prosecute those who attempt to undermine the system to their own financial advantage.”  

This case, 25-cr-4276-H, is being prosecuted by Assistant U.S. Attorneys Joseph S. Smith and Daniel F. Casillas.

JOEM Study Shows Asthma Caused by Cannabis Industry Exposures

A new study published in the Journal of Occupational and Environmental Medicine (JOEM) examines work-related asthma (WRA) among cannabis industry workers, using data from four US state-based surveillance systems (California, Massachusetts, Michigan, and Washington).

WRA cases within the cannabis industry were identified and classified as new-onset asthma or work-aggravated asthma. The findings can be used to guide preventative strategies and inform workplace safety policies to protect workers’ respiratory health.

From legalization dates (1996 in California, 2012 in Massachusetts, 2008 in Michigan, 1998 in Washington) through 2023, 30 WRA cases were identified. A majority were aged 18 to 34 years (66.7%) and were male (60%). Thirteen (52%) cases were new-onset asthma, and 12 (48%) were work-aggravated asthma, with two fatalities. Four case reports, one from each state, present detailed evidence for the association of workplace exposures and work-related asthma.

The most frequently reported exposure was plant materials (40.4%), of which 94.7% were cannabis dust and/or marijuana plant. Most cases (69%) worked in indoor cultivation/processing. 13 cases were new-onset asthma, 12 were work-aggravated asthma, and 5 cases could not be classified. Among the new-onset cases, three had worked in the industry for less than one year.

OSHA recently published an OSHA Fatal Facts report regarding q 27-year-old flower technician, who made “pre-rolls” (ground cannabis cigarettes) in an indoor cannabis cultivation and processing facility, experienced a severe asthma exacerbation at work that resulted in cardiac arrest.

To reduce the incidence of occupational allergies and asthma in this industry, a multifaceted approach is recommended by OSHA

1) Conduct medical screening and surveillance
– – – – Workers experiencing any work-related allergy and/or asthma symptoms noted above should be seen promptly by a healthcare provider with expertise in occupational allergy and asthma
– – – – Jobs with exposure to known allergens, such as cannabis, should have written surveillance programs that periodically assess employees for allergy signs and symptoms and perform medical tests as recommended by an appropriate occupational health professional with expertise in occupational allergy
– – – – Identify jobs causing symptoms in employees so that exposures can be assessed and controlled
2) Assess hazards in jobs that cause symptoms in workers to identify the causative agents involved5,7
3) Implement exposure control with engineering controls, administrative controls including work practices, and personal protective equipment (PPE) as applicable5,7
4) Provide medical management
– – For example, complete cessation of exposure with applicable benefits, rather than exposure reduction and/or respirator use, may be appropriate for workers with occupational allergies
5) Worker training and education should cover
– – Identified job hazards
– – Use of engineering controls, such as local exhaust ventilation, at point of operation
– – Work practices that minimize exposures such as HEPA vacuuming rather than dry sweeping
– – Proper use/care of PPE
– – Signs and symptoms of occupational allergy and the need for prompt employer notification and medical evaluation if symptoms occur
– – Procedures for employees to notify their employer about potential signs and symptoms of occupational allergy

Additionally, employers may also collaborate with academia on preventive efforts and risk factors for occupational allergy in this emerging industry. In particular, information that may support development of diagnostic tests for cannabis sensitization would be useful for future preventive efforts.

November 10, 2025 – News Podcast


Rene Thomas Folse, JD, Ph.D. is the host for this edition which reports on the following news stories: Cal Supreme Court Says Criminal Misgendering Law is Constitutional. Aetna Resolves SoCal Denial of Disc Surgery Class Action. Uber/Lyft Sued for Passenger Gender Preference Programs. Inland Empire Hospice Operators Sentenced in Fraud Case. NYT: “California Promised Insurance Relief, But Delivered Loopholes”. Costco, Ryder Last Mile, Mega Nice Trucking Cited for Misclassification. NCCI Publishes 3rd Quarter Medical Inflation Insights Report. 12,500 Attend World’s Largest Annual Safety Event.