Salley

Salley v. Outfront Media CA2/4

Good Law
Court of Appeal of CaliforniaFebruary 27, 2026B346096California3,958 words

Opinion

Opinion

Tamzarian, J.

BACKGROUND

I. Salley’s Work for Outfront

Outfront is an advertising company that specializes in billboards and transit displays. Salley worked for Outfront (and its predecessors) from 1993 to July 2022. By the end of Salley’s tenure, he was a Senior Account Executive. Salley’s job was to sell Outfront’s advertising space. His duties included finding new clients, servicing accounts to retain clients and ensure they paid their invoices, taking clients to view Outfront’s billboards, developing client proposals, setting prices, identifying locations for ads, and helping to design ads. Salley also ensured Outfront posted the ads and confirmed that with clients. Outfront classified Salley as an exempt outside salesperson. It paid him solely via commissions and bonuses. Outfront expected Salley to spend most of his time working outside its Los Angeles office. At his deposition, Salley testified

2 that he spent about 40 to 50 percent of his time working in the field “[s]eeing clients,” “[s]coping out potential locations,” and monitoring what competitors were doing. He also spent time working remotely on his laptop at home or in his car. At times, he went to Outfront’s office to attend…

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