Review Denied: Dunlap and Koehl

While we were out trying cases, the Supreme Court denied review in Dunlap v. Superior Court (2006) 142 Cal.App.4th 330 (employees need not follow the Labor Code Private Attorneys General Act of 2004's administrative procedures as long as they are not seeking PAGA civil penalties which would otherwise only be available to the Labor Commissioner). And in Koehl v. Verio, Inc. (2006) 142 Cal.App.4th 1313 (upholding verdict determining commission chargebacks to be lawful reimbursement of non-wage advances), a petition for review was denied.