In a rare victory for employers, the Court of Appeal ruled, on February 27, 2023, that an employer’s good faith belief that it complied with California’s wage and hour laws precludes the imposition of waiting-time and wage-statement penalties. See Naranjo v. Spectrum Security Systems, No. B256232, 2023 WL 2261253, at *8 (Cal. Ct. App. Feb. 27, 2023) (certified for publication; citation to official report pending). In Naranjo, the California Court of Appeal held that Spectrum Security’s good faith belief that it had complied with applicable laws supported a finding that it did not act “willfully” or “knowingly and intentionally,” and, therefore, Labor Code section 203 and 226 penalties were not appropriate.
