The Ninth U.S. Circuit Court of Appeals yesterday vacated an attorney fee and cost award of $312,429 to a plaintiff who settled a wage-and-hour dispute with Walmart for $22,000, saying that District Court Judge André Birotte Jr. of the Central District of California failed to set forth a sufficient analysis as to how that number was reached.

Last week, the Committee on Revision of the Penal Code and California Policy Lab published a report looking at the recidivism rates of people resentenced under some of the state’s major criminal justice reforms. The three-year conviction rate for all prisoners released in fiscal year 2018–19 was about 42%, the rate for people released through Prop. 36 was about 25%, with most of those being for misdemeanors.

“Sudden” and “gradual” are antonyms, Div. Three of the Court of Appeal for this district held yesterday, rejecting the contention by Montrose Chemical Corporation of California that its insurance policies cover it for massive environmental damage caused by the slow release of pollutants at its Torrance DDT plant, up until it ceased production in 1982.

Div. One of the Fourth District Court of Appeal held yesterday that violations of a California law, providing that private employers are prohibited from demanding that employees submit to a polygraph test as a condition of employment, may support a claim for wrongful discharge in violation of public policy.