Friday, January 9, 2015

Clarifications Don't Implicate Retroactivity

Satyadi v. W. Contra Costa Healthcare Dist., No. A138948 (D1d5 Dec. 31, 2014)

The state legislature recently amended the Labor Code to make clear that a plaintiff bringing an action under its provisions needs not exhaust any administrative remedies available before the labor commissioner before filing suit. This case addresses the question of whether that amendment applies to cases pending at the time it was passed. The court here holds that it does. 

While statutes are generally presumed not to be retroactive, a legislative clarification of a statute that has received inconsistent treatment by the courts applies to pending cases. That was the case here. A Supreme Court case suggested that exhaustion was required, but did not actually decide the issue. A court of appeal case held that exhaustion was not required. And the federal courts were split on the issue. Since the statutory change was consistent with some of the prior interpretation, it was merely a clarification and thus applied to plaintiff’s pending case.

Reversed. 

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