David Soto filed a class action complaint against his former employers, asserting violations of Labor Code laws governing overtime pay, rest breaks, meal breaks, and minimum wage, as well as a claim alleging those violations constitute unlawful business practices under California’s Unfair Competition Law (“UCL”). After certifying the case as a class action, the trial court ruled the statute of limitations for the UCL claim was three years because the claim was predicated on Labor Code violations. MLG filed a petition for writ of mandate, contending that the statute of limitations for any UCL claim is always four years, regardless of the limitations period of the predicate statute.
The Fourth District Court of Appeal agreed with MLG and granted Soto’s petition. The Court held that “Under established precedent, all UCL claims are subject to a four-year statute of limitations, even when the limitations period for the predicate violation is shorter.” The panel directed the trial court to vacate its order and issue a new order declaring the statute of limitations for the UCL claim is four years.
