While the Ninth Circuit's recent decision in Bernstein v. Virgin America, Inc., et al., ___ F.3d ____, 2021 U.S. App. LEXIS 5197 (9th Cir. Feb. 23, 2021), gave some wins to the airlines, air carriers employing California-based flight crewmembers must, as a practical matter, now abide by the state's stringent wage and hour laws – even if the crewmembers in question perform most of their work out of state. Background Bernstein is a class action brought by flight attendants for Virgin – a former California-based carrier – who alleged that the carrier violated California's wage and hour laws. The primary issue was whether California's wage and hour laws applied. The class members, all of whom were based in