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Monday, November 24, 2025

Employer’s Ignorance of the Law is Not a Good Faith Defense for Failing to Pay Minimum Wages, California Supreme Court Says - CDF Labor Law

Last week, in Iloff v. LaPaille, the California Supreme Court made clear the burden on employers when asserting a good faith defense to avoid paying liquidated damages for violations of minimum wage laws. In its long-awaited decision, the Court established that ignorance of the law is insufficient to establish a defense, and the employer must show that it made a reasonable attempt to determine the requirements of the law.

In this case, the employee, Laurance Iloff, lived and worked on property owned by Bridgeville Properties, Inc., which was managed by Cynthia LaPaille. Bridgeville was in the business of renting small houses and other structures. In exchange for his work on their properties as a maintenance worker, Bridgeville and LaPaille agreed that Iloff could live rent-free in one of the homes. Iloff received no other compensation or benefits.

Years later, Bridgeville terminated this arrangement, and Iloff filed a claim with the Labor Commissioner for unpaid wages and penalties, including a claim under Labor Code section 1194.2 for liquidated damages, which requires employers to pay double for any unpaid minimum wages.

The trial court ruled against Iloff on the issue of liquidated damages, reasoning that the employers had acted in “good faith” by not paying Iloff and had “reasonable grounds” for believing that they were complying with minimum wage laws. The court based its decision on its determination that Iloff and his employers both expected Iloff to perform...



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