When it comes to minimum wage law violations in California, employers should take note that ignorance of the law has been ruled out as a valid good-faith defense to an award of liquidated damages. In Iloff v. LaPaille, the California Supreme Court recently made clear that employers seeking to support a good-faith defense to liquidated damages for minimum wage violations have the burden to show that they made a reasonable attempt to determine the requirements of minimum wage law.
In Iloff v. LaPaille, the plaintiff, Laurance Iloff, lived and worked on property owned by Bridgeville Properties and managed by Cynthia LaPaille. Under an informal arrangement, Ilof's employers allowed him to live rent-free in one of the houses on the property in exchange for maintenance work he performed, but did not provide him with any other benefits or compensation for his services.
Following his termination, Iloff filed wage claims with the Labor Commissioner. The Labor Commissioner found Iloff had been an employee, and awarded unpaid wages, penalties, and interest, as well as liquidated damages. California Labor Code section 1194.2 enables an employee to recover liquidated damages for wage violations, in the amount of wages unlawfully paid plus interest, unless the employer is able to show it acted in good faith and reasonably believed it was following the law.
The employers appealed to the superior court in an administrative process known as the...
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