This California wage and hour Law Firm Publication by Ogletree, Deakins, Nash, Smoak & Stewart, P.C. addresses Mendiola v. CPS Security Solutions, Inc., in which the California Supreme Court held that security guards who worked 24-hour shifts should be compensated for their on-call hours. The court found that on-call time was spent primarily for the employer's benefit and that the restrictions placed on employees during on-call hours showed that they were subject to the employer's control. In addition, the court held that the employer could not exclude the eight hours of sleep time during an employee's 24-hour shift from his compensable hours worked. Federal regulations allowing for the exclusion of sleep time are not incorporated into the California wage orders applicable to the security guards.