Playing the employer name game with itemized wage statement claims

Claims for failure to provide accurate itemized wage statements have been bedeviling California employers for years. Although the statutory requirements are pretty clear, there continues to be some confusion about the information that satisfies an employer's obligation to provide a wage statement that sets forth the name of “the legal entity that is the employer.” The following case provides some clarity on which information does not meet that requirement.

What's in a name?

As we all know by now, the California Legislature has enacted a statutory requirement that employers provide employees itemized wage statements setting forth certain information, including the “name . . . of the legal entity that is the employer.” Mohammed Noori sued his former employer, Countrywide Payroll & HR Solutions, Inc., alleging it violated Labor Code Section 226(a) by providing wage statements bearing the acronym “CSSG.”

Noori claimed that CSSG stands for “Countrywide Staffing Solutions Group,” which is a fictitious business name for Countrywide Payroll & HR Solutions, Inc., but apparently isn't registered as a business name in California. He also asserted that Countrywide failed to maintain copies of accurate itemized wage statements as required by law. Moreover, he sought to bring both claims under the Private Attorneys General Act (PAGA).