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A California appeals court has overturned a large punitive damages jury award in a case involving underpaid wages and missed meal and break periods. Had the court upheld the awards, employers would have had a whole new reason to lose sleep over inaccurate payroll records.

Recent case:
Christine Brewer worked for Premier Golf Properties for many years as a waitress in the clubhouse. When new management changed the concept from a coffee shop to a steakhouse, Brewer chose to work in the newly created café instead. She then hurt her back and was out for a while. When she returned, the café had closed and she was assigned to the morning shift at the steakhouse—a shift she didn’t like because she earned less in tips on that shift.

Brewer quit a few weeks later and then filed a wage-and-hour claim, accusing her former employer of underpaying her hours and not letting her take meal and rest breaks throughout her tenure.

A jury awarded her $1,000 in unpaid wages, $6,000 in unpaid meal and rest beaks and $15,300 in underpaid minimum wages. The jury then tacked on another $195,000 as punitive damages.

The company appealed and won. It argued that it didn’t make sense to punish it further with additional damages far in excess of what it actually owed for its prior wage mistakes. Its rationale: The law already specified the penalties.

The court agreed and said employees can’t get additional payments in the form of punitive damages for California Labor Code violations—just the penalties already built into the law. (Brewer v. Premier Golf Properties, No. D05686, Court of Appeal of California, 4th Appellate District, 2008)

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