This Law Firm Publication by Ogletree, Deakins, Nash, Smoak & Stewart, P.C. discusses the recent California decision, Cochran v. Schwan's Home Service, Inc. In that case, the California Court of Appeal of California, Second Appellate District, Division Two considered whether an employer is required to pay an employee for the mandatory use of the employee's cell phone for business purposes, even if the employee incurred no extra expenses in using the phone. The court reversed the trial court and held that, in accordance with California Labor Code section 2802, employers must always reimburse employees for the mandatory use of personal cell phones, even if an employee has unlimited cell phone minutes. The court approached the issue from the standpoint that failing to reimburse employees would result in the employer unfairly passing its expenses on to the employees. The court did not define the term mandatory, or specify how employers should calculate the reimbursement to each employee.