Carlos Cifuentes won a judgment for lost wages against his former employer, Costco. Costco withheld federal and state payroll taxes from the award in response to which Cifuentes claimed the judgment was not satisfied, citing a 1992 appellate court opinion holding that an employer is not required to withhold payroll taxes from an award of lost wages to a former employee. The trial court determined the withholding was improper and denied Costco’s motion for acknowledgement of satisfaction of the judgment, but the Court of Appeal reversed, holding that “an employer who fails to withhold payroll taxes from an award of back or front pay to a former employee exposes itself to penalties and personal liability for those taxes” and expressly declined to follow the earlier opinion of the Court of Appeal. See also Rodriguez v. Cho, 236 Cal. App. 4th 742 (2015) (default judgment is set aside because it exceeded the amount demanded in the complaint).