In August, a California appellate court held in Cochran v. Schwan's Home Service, Inc. that employers must reimburse employees for mandatory use of personal cell phones for business purposes, even if employees have unlimited plans and otherwise incur no additional out-of-pocket expenses for such use. The California Supreme Court refused to grant review of the decision, such that it will stand as established case law. See our September edition for a discussion of this case.

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