Motion For Class Certification Denied.

The trial court denied class certification in a wage and hour case, and the appellate court, finding no abuse of discretion, affirmed. The crux of the analysis was that the employer had express written policies regarding work and meal breaks, but that some managers imposed uncompensated-for duties to be followed by the employees during their breaks. The Court of Appeal agreed with the trial court that there was evidence the policies in fact varied and were anything but uniform, thus, making the case difficult to manage as a class action. (Koval v. Pacific Bell Telephone Co. (Cal. App. First Dist., Div. 1; December 31, 2014) 232 Cal.App.4th 1050, [181 Cal.Rptr.3d 805].)