The case involved Sharmalee Goonewardene, who had sued her former employer, travel company Altour International, for discrimination, missed overtime and breaks, wrongful termination, and other claims. She added ADP as a defendant, claiming the payroll company committed unfair business practices for not giving her accurate checks. The lower court had held that the payroll company owed her a duty of care as a third-party beneficiary of the contract between Goonewardene’s employer and ADP. However, the California Supreme Court reversed the court of appeal holding that an employee who believes he or she has not been paid the wages due under applicable law may not maintain a causes of action for unpaid wages against the payroll provider for breach of contract, negligence or negligent representation. Read more here.