Soto v. Motel 6 Operating, L.P., 4 Cal. App. 5th 385

Plaintiff Lidia Soto worked for Motel 6 from June 2012 to January 2015 and sued in May 2015.
Soto brought an individual and representative PAGA action alleging violation of Labor Code §226(a) for failing to list monetary amounts of accrued vacation/PTO on semi‑monthly wage statements.
Motel demurred, arguing §226(a) does not require reporting the monetary value of accrued vacation/PTO before employment termination.
Trial court sustained the demurrer without leave to amend, concluding §226(a) need not include accrued vacation values on wage statements.
On appeal the Court of Appeal applied de novo review and affirmed, holding accrued vacation monetary value need not be listed until a payment is due at termination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §226(a) requires itemizing the monetary value of accrued vacation/PTO on each wage statement	Soto: “wages” includes vacation pay; §226(a) requires itemization of earned wages each pay period	Motel: §226(a) lists specific required items and does not include accrued vacation; vacation pay becomes a wage only at termination under §227.3 and case law	No — §226(a) does not require listing monetary value of accrued vacation/PTO until payment is due at employment termination

Murphy v. Kenneth Cole Prods., 40 Cal.4th 1094 (Cal. 2007) (recognizing vacation pay as a form of "wages" in certain contexts)
Suastez v. Plastic Dress‑Up Co., 31 Cal.3d 774 (Cal. 1982) (vacation pay characterized as deferred wages that vest as services are performed)
Church v. Jamison, 143 Cal.App.4th 1568 (Cal. Ct. App. 2006) (unused vacation converts to a monetary obligation upon termination)
Gattuso v. Harte‑Hanks Shoppers, Inc., 42 Cal.4th 554 (Cal. 2007) (principles of statutory interpretation and legislative intent)
Morgan v. United Retail, Inc., 186 Cal.App.4th 1136 (Cal. Ct. App. 2010) (purpose of §226 to document basis of compensation and assist employees in verifying pay)