Meda v. AutoZone, Inc., 81 Cal. App. 5th 366 (2022)

Monica Meda worked as a sales associate at an AutoZone for approximately six months before quitting and suing for violation of the Private Attorneys General Act (“PAGA”), asserting AutoZoners (the operating company for AutoZone) had failed to provide suitable seating to employees at the cashier and parts counter workstations.  AutoZoners obtained summary judgment in the trial court on the ground that Meda had no standing to bring a PAGA action because it satisfied the seating requirement by making two chairs available to its associates.  However, the two chairs were not placed at the cashier or parts counter workstations (they were outside the manager’s office), and Meda contended no one told her the chairs were available for use at the front counter workstations, and she never saw anyone else use a chair at those workstations.  The Court of Appeal reversed the summary judgment and held that “where an employer has not expressly advised its employees that they may use a seat during their work and has not provided a seat at a workstation,” the inquiry as to whether the employer has “provided” suitable seating may be “fact-intensive and may involve a multitude of job- and workplace-specific factors,” making resolution at the summary judgment stage “inappropriate.”