Employment Litigation · Primary-source case analysis

Naranjo v. Spectrum: Meal-Period Premium Pay Is a Wage

By Aneeta Mishra and Timothy Chan

Published April 14, 2026

Naranjo resolved whether the hour of premium pay due for a noncompliant meal or rest period is only a statutory remedy or also compensation for work.

The dispute over derivative remedies

Employees sought meal-period premium pay and argued that unpaid premiums also supported waiting-time penalties and wage-statement remedies. The lower courts disagreed about whether the premium was a wage that had to be paid and reported as such.

The premium serves two functions

The Supreme Court concluded that section 226.7 premium pay compensates the employee for work performed during a period that should have been free of work, while also encouraging compliance. Its compensatory function makes the amount a wage.

Consequences for final pay and statements

Because the premium is a wage, it must be considered under the statutes governing timely final payment and accurate wage statements. Liability under those provisions still depends on their own requirements, including the applicable state of mind and injury elements.

Disposition and later proceedings

The Court affirmed in part, reversed in part, and remanded. The opinion established the wage character of premium pay but did not automatically impose every derivative penalty on every employer whenever a break violation occurs.

Key takeaways

• Meal- and rest-period premiums are wages.
• Unpaid premiums can affect final-pay and wage-statement analysis.
• Each derivative remedy retains separate statutory elements.
• Time and payroll records should be reviewed together.