In Iloff v. LaPaille, the Supreme Court today rules in favor of employees on issues regarding violations of minimum wage laws and of the Paid Sick Leave law.
The court’s unanimous opinion by Justice Joshua Groban concludes an employer can establish a good faith defense to a liquidated damages claim for a minimum wage violation (Labor Code section 1194.2 [the claim is for “an amount equal to the wages unlawfully unpaid and interest thereon”]) only by showing “it made a reasonable attempt to determine the requirements of the law governing minimum wages; proof that the employer was ignorant of the law is insufficient.”
In the case before it, the court found unavailing evidence that the employers and the employee “intended and expected that [the employee] would perform his services in exchange for free rent and that he would not be paid wages or otherwise treated as an employee.” The opinion interprets Labor Code provisions as “suggest[ing] that the Legislature intended for employers to be liable for liquidated damages even when their employees have agreed to work for less than the minimum wage.”
The court also decides that an employee can raise a claim for penalties under the Paid Sick Leave law when responding to an employer’s superior court appeal of a Labor Commissioner ruling awarding unpaid wages, liquidated damages, penalties, and interest. The Paid Sick Leave law requires employers to provide paid leave for health-related reasons or to care for sick family members.
The court reverses the First District, Division One, published opinion in the case.
