On April 10, 2019, a court of appeal in Savea v. YRC Inc. affirmed a lower court’s dismissal of a lawsuit brought under the Private Attorneys General Act (PAGA) by an employee on behalf of himself and as an “aggrieved employee” that alleged that the employer’s wage statements “do not accurately show the name of the legal entity that is the employer” and “fail to completely and accurately show the employer’s address.” The wage statements referenced the employer’s name as YRC Freight, while the entity registered with the California Secretary of State was YRC Inc., and while it showed its correct address, it did not reference “a mail stop code and a ZIP+4 Code.”
The Savea court held that the name the employer listed on the wage statements given to its employees was its actual, recorded fictitious business name, which it was permitted for use on official documents, its address was its proper mailing address, and Labor Code section 226(a) did not require an employer to use a mail stop code or the “ZIP+4″ format for the zip code. In a footnote, the Savea court stated that it was not necessary for it to decide whether Labor Code section 226(a) required “strict” or “substantial” compliance because it affirmed the trial court’s determination that YRC “did strictly comply” with the law.