Craib v. Bulmash

777 P.2d 1120, 49 Cal. 3d 475, 261 Cal. Rptr. 686, 29 Wage & Hour Cas. (BNA) 705, 1989 Cal. LEXIS 1601
CourtCalifornia Supreme Court
DecidedAugust 28, 1989
DocketS004682
StatusPublished
Cited by21 cases

This text of 777 P.2d 1120 (Craib v. Bulmash) is published on Counsel Stack Legal Research, covering California Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Craib v. Bulmash, 777 P.2d 1120, 49 Cal. 3d 475, 261 Cal. Rptr. 686, 29 Wage & Hour Cas. (BNA) 705, 1989 Cal. LEXIS 1601 (Cal. 1989).

Opinions

Opinion

EAGLESON, J.

This case concerns the circumstances under which an employer may assert the Fourth and Fifth Amendments to the United States Constitution as defenses to judicial enforcement of an administrative agency’s subpena duces tecum for records of a kind which all employers are required by law to maintain.

[478]*478We first reject the employer’s claim that a court order compelling compliance with the agency’s subpena is an “unreasonable search and seizure” under the Fourth Amendment unless supported by “probable cause.” Forty years of United States Supreme Court decisions establish that the subpenaed records need only be relevant to an authorized regulatory purpose and described with reasonable specificity. While this approach traditionally has been applied in the context of subpenaed corporate records, we see no reasoned basis for departing from precedent solely because the instant employer is an individual, rather than a corporation. Further, there is no reasonable expectation of privacy against judicially compelled disclosure of records required to be kept, and subject to administrative subpena, under a lawful regulatory scheme.

Also, consistent with the traditional exemption of “required records” from the Fifth Amendment privilege against compulsory self-incrimination, an employer must unconditionally respond to a court order enforcing an agency’s subpena for wage and hour records which the employer is statutorily required to maintain. The privilege does not apply where, as here, the reporting requirement is intended to promote a legitimate regulatory aim, is not directed at activities or persons that are inherently “criminal,” and only requires minimal disclosure of information of a kind customarily kept in the ordinary course of business.

The Court of Appeal therefore erred in relying on the Fourth and Fifth Amendments to reverse a court order compelling the employer to comply with the instant administrative subpena. We will reverse the judgment of the Court of Appeal.

Background

The Division of Labor Standards Enforcement (Division) is charged with enforcing Labor Code provisions (§ 1171 et seq.)1 and Industrial Welfare Commission (Commission) orders governing wage, hour, and working conditions of California employees. (§61.) The Division has broad investigatory powers (§ 1193.5) and duties (§§ 1195, 1195.5), including the power to issue subpenas compelling the attendance of witnesses and production of records. (§§ 7, 74.)2 The statutory scheme requires “[e]very person employ[479]*479ing labor in this state” to maintain certain employee identification and payroll records. (§ 1174, subds. (c), (d).)3 An employer who fails or refuses to maintain and furnish these records is guilty of a misdemeanor. (§ 1175, subds. (a), (d).)4 The Division also has a variety of means by which to enforce the substantive wage and hour provisions, including civil actions to recover unpaid wages (§§ 1193.6, 1194), actions for injunctive relief (§ 1194.5), “civil” monetary penalties (§ 1197.1), and misdemeanor sanctions (§ 1199).5

Here, Jay S. Bulmash (Bulmash) was appointed trustee for his sister, Serena Gluck (Gluck), and employed attendants to care for her. In February 1986, Deputy Labor Commissioner Donald C. Craib (Commissioner) issued and served6 a subpena duces tecum directing Bulmash to appear at the Division’s Santa Barbara offices one month later and to produce time and wage records, and names and addresses, for all persons employed by the trust over the previous three-year period. In an attached declaration, the Commissioner stated that the documents were needed to “verify wages and compute unpaid overtime pay for private household employees covered under Industrial Welfare Commission Order 15-80 and employed by Jay S. Bulmash as trustee for Ser[e]na B. Gluck.” Order 15-807 requires that such records be maintained for a minimum of three years.

[480]*480After Bulmash failed to appear as requested, the Commissioner filed an unverified petition8 in the superior court seeking to enforce the subpena. The petition alleged that the subpena and investigation were authorized under the statutory provisions cited above. According to the petition, the investigation began after a “former employee” of the trust lodged a complaint against Bulmash for “failure to pay overtime wages as required by Industrial Welfare Commission Order 15-80.” In points and authorities supporting the petition, the Commissioner argued there was “probable cause” to suspect that Bulmash was “in violation of certain sections of the Labor Code [concerning] payment of wages for hours worked.” The petition itself further averred that the subpenaed records were necessary to determine whether the alleged violation had occurred. No affidavits by the complaining trust employee or by Division staff members supported the foregoing statements.

In written opposition to the petition, Bulmash argued that the subpena was “overbroad,” that compliance would be “burdensome,” and that the records were not “relevant” to any matter pending before the Division. Bulmash also insisted that because the subpena was issued without “probable cause,” court-ordered compliance would amount to an “unlawful search and seizure.” After a brief hearing, the court ordered Bulmash to appear before the Commissioner and produce the subpenaed records.

On appeal, Bulmash reiterated his claim that the Fourth Amendment precluded enforcement of the subpena because no sworn factual statement establishing probable cause accompanied the Commissioner’s petition. The Court of Appeal agreed and reversed the order. The court reasoned that, because “criminal” sanctions could be imposed for certain wage and hour violations, the subpena was a “search” for criminal “evidence” which must meet the standards applicable to search warrants. At the urging of both parties, the court also addressed the question whether enforcement of the subpena would violate Bulmash’s Fifth Amendment privilege against compulsory self-incrimination.9 The court answered this question in the affirmative, apparently concluding that both the contents of the records and the compulsory act of production amounted to incriminating testimony of Bulmash’s failure to pay the appropriate wage.

[481]*481Discussion

A. Fourth Amendment

The Commissioner essentially concedes that the instant subpena fails to comply with literal Fourth Amendment requirements for a criminal warrant issued only “upon probable cause, supported by oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.” He insists, however, that judicial enforcement of the subpena is constitutionally permissible under a standard which is less exacting than that required for a search in a criminal prosecution. Based on a recent line of cases by the United States Supreme Court, we agree.

As Bulmash suggests, it was once assumed that the compulsory production of records was a “search and seizure” in the literal Fourth Amendment sense (see, e.g., Boyd v. United States (1886) 116 U.S. 616, 622 [29 L.Ed. 746, 761, 6 S.Ct.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

P. ex rel. Bonta v. Greenpower Motor Co., Inc.
California Court of Appeal, 2025
McCracken v. Riot Games CA2/7
California Court of Appeal, 2023
Kennedy v. Ramirez CA1/5
California Court of Appeal, 2020
City and County of S.F. v. Uber Technologies
California Court of Appeal, 2019
City of S.F. v. Uber Techs., Inc.
248 Cal. Rptr. 3d 273 (California Court of Appeals, 5th District, 2019)
Sue v. The Monsoon Blue CA2/7
California Court of Appeal, 2016
State Ex Rel. Department of Pesticide Regulation v. Pet Food Express Ltd.
165 Cal. App. 4th 841 (California Court of Appeal, 2008)
City of Santa Cruz v. Patel
65 Cal. Rptr. 3d 824 (California Court of Appeal, 2007)
In Re Alva
92 P.3d 311 (California Supreme Court, 2004)
Opinion No. (2003)
California Attorney General Reports, 2003
MacHado v. State Water Resources Control Board
109 Cal. Rptr. 2d 116 (California Court of Appeal, 2001)
De La Cruz v. Quackenbush
96 Cal. Rptr. 2d 92 (California Court of Appeal, 2000)
People v. Kroncke
83 Cal. Rptr. 2d 493 (California Court of Appeal, 1999)
Dep't of Indus. Relations v. UI Video Stores, Inc.
55 Cal. App. 4th 1084 (California Court of Appeal, 1997)
Millan v. Restaurant Enterprises Group, Inc.
14 Cal. App. 4th 477 (California Court of Appeal, 1993)
Pacific-Union Club v. Superior Court
232 Cal. App. 3d 60 (California Court of Appeal, 1991)
Pinney v. Phillips
230 Cal. App. 3d 1570 (California Court of Appeal, 1991)
Wang v. Division of Labor Standards Enforcement
219 Cal. App. 3d 1152 (California Court of Appeal, 1990)
Craib v. Bulmash
777 P.2d 1120 (California Supreme Court, 1989)

Cite This Page — Counsel Stack

Bluebook (online)
777 P.2d 1120, 49 Cal. 3d 475, 261 Cal. Rptr. 686, 29 Wage & Hour Cas. (BNA) 705, 1989 Cal. LEXIS 1601, Counsel Stack Legal Research, https://law.counselstack.com/opinion/craib-v-bulmash-cal-1989.