A recent court decision highlights the complex nature of employment agreements and the fine line between personal assistance and professional obligations. The California Court of Appeal, Second Appellate District, Division Six, ruled on August 19, 2024, in favor of a defendant who had previously been awarded $96,412 by a superior court after a trial de novo. This judgment followed an appeal by Andrew Santer and Sondra Santer against a California Labor Commissioner decision that initially favored the defendant.
The case revolves around Vicki Huff, who responded to an advertisement posted by Andrew Santer seeking assistance for his elderly mother, Sondra Santer. The ad called for "a senior woman to share [Leisure Village] home with current senior woman owner" and included duties such as light housework between 10 a.m. and 7 p.m. Huff accepted the position under a "roommate agreement," which explicitly stated that it was not an employment contract and that she would pay no rent in exchange for providing custodial support.
Huff moved into the Leisure Village home and began her duties but soon found herself restricted from leaving the house for more than two hours on non-working days unless she was engaged in charity work. Believing she was entitled to wages for her services, Huff filed a claim with the California Labor Commissioner. The hearing officer ruled in her favor, awarding her $362,170.07 for unpaid wages, overtime, liquidated damages, interest, and waiting time penalties.
However, the Santers appealed this decision to the superior court for a trial de novo. During this trial, Huff testified about her understanding of her working hours based on communications with Andrew Santer. She cited an August 27, 2019 text message where Santer expressed concern over her being out for four hours during what he considered working hours.
Despite Huff's claims that she was essentially on call 24/7 due to these restrictions and occasional nighttime assistance provided to Sondra Santer, both Andrew and Sondra testified otherwise. They argued that Huff's primary responsibilities were limited to daytime hours specified in the ad and that any additional help at night was expected as part of being a roommate rather than an employee.
The trial court ultimately found substantial evidence supporting this interpretation. It ruled that Huff's working hours were from 9:00 a.m. to 7:00 p.m., rejecting her claim of being required to work around-the-clock as an on-call employee. Consequently, Huff was awarded $96,412 instead of the initial amount determined by the Labor Commissioner.
In its discussion, the appellate court emphasized that it does not weigh evidence or resolve conflicts but supports reasonable inferences drawn by the trial court. The judges noted that while Huff did provide some after-hours assistance occasionally, these instances did not constitute regular or expected work duties extending beyond her designated working hours.
Representing Vicki Huff were attorneys from The Law Office of Louis H. Kreuzer II while Andrew and Sondra Santer were represented by attorneys from Law Offices of David A. Esquibias and Christopher A. Fortunati. The case was presided over by Judge Henry J. Walsh in Ventura County Superior Court under Case ID No. B331044.