In Securitas Security Services USA, Inc. v. Superior Court (Holland), security guards brought an action against their employer alleging a failure to pay split shift pay per Wage Order No. 4, which defines a "split shift" as "a work schedule" that "is interrupted by non-paid non-working periods established by the employer, other than bona fide rest or meal breaks."  The term "work schedule" is not defined in either the wage order or the Labor Code, and Plaintiffs argued that it should be defined as a calendar workday.  The California Court of Appeal held that split shift pay is required only when an employee's actual work shift is split, and not simply because an employee's shift carries over from one workday to the next.