Sirius XM Radio and Pandora Media's summary judgment win in wage and hour PAGA matter upheld by 9th Circuit

Client(s) Sirius XM Radio Inc.

In March 2024, the 9th Circuit Court of Appeals affirmed Jones Day clients Sirius XM Radio Inc.’s and Pandora Media, LLC’s summary judgment win dismissing all claims in this putative class and PAGA representative wage and hour action. The plaintiff alleged California Labor Code violations for failure to reimburse necessary business expenses and failure to furnish accurate wage statements, as well as derivative claims. The plaintiff claimed, among other things, that she was entitled to reimbursement for expenses she incurred while working from home during the COVID-19 Pandemic, including rent/mortgage, furniture, electricity, gas, Internet, and mobile expenses. The district court granted summary judgment in the Companies’ favor, concluding that defendants lacked knowledge of any purported business expenses that were incurred, that the Companies complied with applicable wage statement requirements, and that Plaintiff failed to establish any injury under the wage statement laws. On appeal of the dismissed expense claim, the 9th Circuit Court of Appeals upheld the district court’s ruling that the Companies lacked requisite knowledge of any purported expense, and affirmed the judgment.

Potts v. Sirius XM Radio Inc., et al., No. 23-55282 (9th Cir.); No. 2:2022cv08907 (C.D. Cal.)