Behrend v. San Francisco Zen Center Inc. CA1/4
MEMORANDUM OPINION1 Alexander Behrend appeals a judgment entered in favor of the San Francisco Zen Center Inc. (Center) and individual defendants Linda Galijan and Mike Smith on his claims for unpaid wages and related interest and penalties under Labor Code2 sections 98.1, 203, and 1194.2. He contends the trial court erred in concluding that his claims were barred by the “ministerial exception”—a constitutional doctrine that provides a
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