GUSTAVO NARANJO et al., Plaintiffs and Appellants, v. SPECTRUM SECURITY SERVICES, INC., Defendant and Appellant., 15 Cal. 5th 1056

Summary

HOLDINGS: [1]-An employer did not knowingly and intentionally fail to comply under Lab. Code, § 226, subd. (e)(1), by not including unpaid meal premiums in its workers' wage statements because it reasonably and in good faith believed it was providing complete and accurate wage statements in compliance with § 226, subd. (a), as shown by its assertion of reasonable legal arguments to support its mistaken belief that it did not owe its workers premium pay for missed meal breaks; [2]-Because a reasonable and good faith dispute provided a defense under Cal. Code Regs., tit. 8, § 13520, to penalties for willful nonpayment of wages under Lab. Code, § 203, and workers often brought claims for violations of Lab. Code, §§ 203, 226, deriving from the same primary violations of the Labor Code, the two penalty provisions were best read to harmonize them by recognizing a good faith defense to both.