Bellflower Unified School Dist. v. Meeks CA2/2

FACTS

Karl Meeks works for the Bellflower Unified School District (BUSD). BUSD provided Meeks with keys to its campus. Meeks signed a “Key Requisition/Loss Form” (the Key Form).2 He chose not to check a box stating, “I do not wish to be issued a key. I prefer that the site staff unlock and lock my door.” Meeks lost BUSD’s keys. As a result, locks were changed in eight classrooms and other facilities: at $150 per room, the total cost was $1,200. BUSD deducted $1,200 from Meeks’s paycheck to recoup the cost of rekeying school locks. BUSD did not obtain a court judgment against Meeks before seizing his wages. Meeks filed a claim with the Commissioner of Labor (the Commissioner) seeking reimbursement of the paycheck deduction. The Commissioner awarded Meeks the full $1,200, plus interest. BUSD sought de novo review in the trial court.

THE TRIAL COURT’S RULING

The trial court found that Meeks is employed as a teacher; his union’s collective bargaining agreement allows members to agree salary deductions; BUSD policy requires employees to sign the Key Form, allowing them to elect or decline keys; employees who receive keys consent to payroll deductions to cover the cost of rekeying in…