Martinez v. Sierra Lifestar, Inc., 119 Cal. App. 5^th 1303 (2026)

Adam Martinez filed this putative class action against Sierra Lifestar, alleging the employer improperly excluded bonuses when calculating employees’ regular rate of pay for purposes of overtime. The trial court denied Martinez’s motion for class certification on the ground that his claims were not typical of the putative class because he had received a particular bonus that was in the nature of a gift and/or was discretionary. The Court of Appeal reversed, holding that the issue of whether employees’ various bonuses should have been included in the regular rate of pay applied to all employees in the putative class and, therefore, was not unique to Martinez.