Iloff v. LaPaille (SC S275848 per curiam 8/21/25) Minimum Wage and Paid Sick Leave | Good Faith Defense to Liquidated Damages – Employment Law Weekly

Iloff v. LaPaille (SC S275848 per curiam 8/21/25) Minimum Wage and Paid Sick Leave | Good Faith Defense to Liquidated Damages

This case addresses two issues concerning the rights of California workers whose employers fail to pay them the minimum wage or provide them paid sick leave benefits.  The first issue relates to the good faith defense to the default rule that employees who prove minimum wage violations are entitled to liquidated damages.  (Labor Code, § 1194.2.)  We hold that to establish the good faith defense, an employer must show that 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.  The second issue relates to the process for raising claims under the Healthy Workplaces, Healthy Families Act of 2014 (§ 245 et seq.; the “Paid Sick Leave law”).  Specifically, we must determine whether a court may consider a Paid Sick Leave law claim that an employee raises in the context of their employer’s appeal to the superior court of a Labor Commissioner ruling.  (§ 98.2, subd. (a).)  We hold that a court may do so.  The Court of Appeal reached the opposite conclusion on both issues, so we reverse.

https://www4.courts.ca.gov/opinions/documents/S275848.PDF

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