According to the California Supreme Court’s Conference Results posted today, the court has denied review in Brewer v. Premier Golf Properties, a case we previously blogged about here and here.

Among other things, the Court of Appeal’s opinion in Brewer held that punitive damages are unavailable in an action for violations of statutes and regulations governing pay stubs, minimum wages, and meal and rest breaks. The court concluded that, because those statutes and regulations created new rights that did not exist at common law, the statutory remedies for violations of meal/rest break, minimum wage, and pay stub laws are the exclusive remedies. Also, the court held that punitive damages are unavailable for these sorts of claims because they ultimately arise from a contractual obligation, whereas Civil Code section 3294 provides that punitive damages are only available for the breach of an obligation not arising from contract.