Seviour-Iloff v. LaPaille
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BPI owned property in unincorporated Humboldt County, with eight rental units, a post office, and its own water system. LaPaille served as CEO and CFO of BPI. From 2009-2016, Laurance and Elsie (plaintiffs) performed work for BPI, managing the water system and serving rent notices. BPI terminated their work when it suspected Laurance was not performing his maintenance jobs, was stealing supplies, and was using BPI’s water rights for a private venture. Plaintiffs were not paid for any work they performed for BPI apart from receiving free rent.
Plaintiffs filed complaints, seeking regular and overtime wages, liquidated damages, and waiting time penalties. The Labor Commissioner agreed and found LaPaille personally liable. The superior court concluded plaintiffs were BPI employees, entitled to minimum wages a certain number of hours per week, with interest on those amounts. It awarded statutory damages for BPI’s failure to provide a wage statement, waiting time damages, and travel expense reimbursements. The court concluded BPI acted in good faith, with reasonable grounds to believe it was not violating the Labor Code, and declined to award liquidated damages and penalties. It concluded LaPaille was not personally liable.
The court of appeal reversed in part. The trial court miscalculated the statute of limitations, erred in declining to impose personal liability on LaPaille, and improperly calculated waiting time penalties.
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