4 Years Later, Martinez V. Combs Still Confusing

Law360, New York (November 6, 2014, 11:38 AM EST) -- Two recent decisions by the California Court of Appeal for the Second District illustrate the far-reaching significance of the California Supreme Court's 2010 decision in Martinez v. Combs.

In Martinez v. Combs, a group of seasonal agricultural workers sued a farming company and two produce merchants who purchased produce from the farming company to recover unpaid minimum wages under California Labor Code Section 1194 and other theories.[1] The merchant defendants moved for summary judgment, arguing they were not liable under Section 1194 because they did not employ the plaintiffs. In response, the plaintiffs argued that the merchant defendants could be liable...

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