A Costly Lesson: Pay an Employee All Wages Owed When Employment Ends

A recent decision by a California court of appeal illustrates the importance of an employer paying an employee all wages owed in a timely manner when the employment relationship is severed. In Stratton v. Beck, an employee of two months filed a claim with the California DLSE alleging that he was still owed $303.50 in wages by his employer after he had quit. Following an administrative hearing, the Labor Commissioner awarded Stratton the unpaid wages he had requested, plus liquidated damages, interest, and statutory penalties, for a total of $6,060.96. Beck appealed the award to superior court where the trial judge awarded Stratton $6,778.85, plus $31,365 in attorney fees because he was a “successful” employee in court. Beck then unsuccessfully appealed the trial court’s judgment, resulting in an additional award of $57,420 in post-judgment and appellate attorney’s fees to Stratton. Beck then filed a motion for reconsideration in the trial court which was denied, resulting in $9,090 more in attorney’s fees being awarded to Stratton. On January 2, the Stratton court published its decision affirming the order of the trial court and rejecting Beck’s latest appeal, and awarded Beck his “costs of appeal” (which will likely result in another request for attorney’s fees by Stratton).