In Curtis v. Irwin Industries, Inc, the Court held that California overtime law does not apply to an employee working under a qualifying collective bargaining agreement. Plaintiffs worked for a company that conducted operations on oil platforms located off the coast of California, on the Outer Continental Shelf. They sued for wage/hour violations. The panel held that plaintiffs’ claim for overtime pay was preempted under § 301 of the Labor Management Relations Act because California overtime law does not apply to an employee working under a qualifying collective bargaining agreement; therefore, plaintiffs’ right to overtime existed solely as a result of their CBAs. The Court remanded to the district court to review meal and rest period and minimum wage claims, as well as derivative claims, and address issues of preemption under § 301 and the Outer Continental Shelf Lands Act, as well as issues of California labor law.

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