Contreras v. Green Thumb Produce, Inc., 116 Cal. App. 5^th 1251 (2025)

Manuel Contreras mistakenly determined that his former employer (Green Thumb Produce) was violating the state’s Equal Pay Act (EPA) by paying him less than his coworkers who were performing similar duties. Contreras did not understand that the EPA prohibits variations in wages based on “gender, race, or ethnicity,” yet none of those grounds existed vis-à-vis Contreras. After Contreras received a verdict of more than $182,000 from a jury, Green Thumb filed a successful motion for partial judgment notwithstanding the verdict (JNOV), claiming the verdict on the whistleblower claim was unsupported because Contreras had misunderstood the EPA. The Court of Appeal reversed the JNOV ruling, holding that Contreras (who had a 10^th grade education) had “reasonable cause” to believe his former employer violated the EPA, notwithstanding his misinterpretation of that law.