Plaintiff Laurance Iloff filed wage claims with the Division of Labor Standards Enforcement (DLSE) against defendants Bridgeville Properties, Inc. (BPI) and its officer Cynthia LaPaille for unpaid wages in violation of the Labor Code. After Iloff received a favorable order from the Labor Commissioner, defendants appealed to the superior court. Following a de novo trial on the wage claims, the court found Iloff was entitled to unpaid wages and certain penalties but rejected his claims under California’s Unfair Competition Law (Bus. & Prof. Code, § 17200 et seq.) (UCL), refused to impose personal liability on LaPaille, and declined to award other penalties.
Iloff appealed, arguing the trial court (1) miscalculated the statute of limitations when awarding unpaid wages; (2) erred in declining to impose personal liability on LaPaille; (3) abused its discretion in denying his UCL claims; (4) erred in declining to award liquidated damages under Labor Code section 1194.2; (5) erred in denying Iloff’s request for administrative penalties under section 248.5; and (6) miscalculated the waiting time penalties under section 203.
We issued an opinion in the appeal. (Seviour-Iloff v. LaPaille (2022) 80 Cal.App.5th 427.) The California Supreme Court granted review on the issues of liquidated damages under section 1194.2 and administrative penalties under section 248.5, and reversed and remanded to this court for further proceedings consistent with its opinion. (Iloff v. LaPaille (2025) 18 Cal.5th 551, 558, 575 (Iloff).)
Accordingly, we now conclude as follows. The trial court miscalculated the statute of limitations to undervalue its award of unpaid wages, and erred in declining to impose personal liability on LaPaille. It did not abuse its discretion in denying Iloff’s UCL claims. The court also erred in declining to award liquidated damages under section 1194.2, denying administrative penalties under section 248.5, and miscalculating the waiting time penalties under section 203.
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