In August, we discussed the California Supreme Court’s ruling addressing the circumstances under which a non-California resident can be covered by that state’s employee-friendly Labor Code. Sullivan v. Oracle Corp., 51 Cal. 4th 1191 (2011). Yesterday, the Court of Appeals for the Ninth Circuit adopted the state court’s ruling, rejecting Defendant’s constitutional challenges to that decision. Sullivan v. Oracle Corp., 2011 U.S. App. LEXIS 24625 (9th Cir. Dec. 13, 2011). California-based employers must be mindful of Sullivan‘s applicability to their non-California employees.