California employers may not obtain an investigative consumer report to aid them in making employment decisions without complying with the Investigative Consumer Reporting Agencies Act (ICRAA). (Civ. Code, § 1786, et seq.) An employer who fails to comply with any of ICRAA’s requirements is liable to the consumer who is the subject of the report for “[a]ny actual damages sustained . . . as a result of the failure or, except in the case of class actions, ten thousand dollars ($10,000), whichever sum is greater.” (§ 1786.50, subd. (a)(1), italics added.) We hold ICRAA, by its plain language, authorizes consumers to recover the statutory sum as a remedy for a violation of their statutory rights, without any further showing of injury. We thus conclude the trial court erred when it required a consumer to demonstrate a concrete injury, such as an adverse employment decision, to establish ICRAA standing and reverse its grant of summary judgment in favor of the employer.
Sheriff Deputies’ Built-In Overtime Counts Toward OCERS Pensions
Under the County Employees Retirement Law of 1937 (CERL), an Orange County employee’s pension is based in part on “compensation earnable,” defined by Government Code section
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