State Overtime Law Does Not Apply To
 Employees Covered By Collective Bargaining Agreement

In Vranish v. Exxon Mobil Corp., 223 Cal. App. 4th 103 (2014), George Vranish, Jr., and Steve Teague are employees of Exxon Mobil whose employment is governed by the terms of a collective bargaining agreement (“CBA”). Plaintiffs contend that the CBA does not provide premium compensation for all “overtime hours worked” and, therefore, Cal. Lab. Code § 514 (exempting employees subject to a CBA from the state’s overtime law) does not apply.

The trial court granted the employer’s summary judgment motion, and the Court of Appeal affirmed on the ground that the word “overtime” as used in Section 514 is defined by the CBA and not by Cal. Lab. Code § 510. See also Sandifer v. United States Steel Corp., 571 U.S. ___, 134 S. Ct. 870 (2014) (unionized steelworkers’ donning and doffing of protective gear constituted non-compensable time spent “changing clothes” within the meaning of the Fair Labor Standards Act).