Iloff v. LaPaille, 2025 WL 3718335 (Cal. Ct. App. 2025)
Laurence Iloff performed maintenance on various structures that were located on property that was owned by Bridgeville Properties, Inc. (BPI) and managed by Cynthia LaPaille. Under an informal arrangement, Iloff’s employers allowed him to live rent-free in one of the houses on the property but did not provide him with any other benefits or compensation for his services. After his employers terminated the arrangement, Iloff filed claims against them with the California Labor Commissioner. The employers contended that Iloff had been an independent contractor, but the Labor Commissioner determined he was an employee and was entitled to unpaid wages, liquidated damages and penalties. Following a bench trial, the superior court found that Iloff was an employee and awarded him unpaid minimum wages. The trial court also found that LaPaille was not personally liable for BPI’s failure to pay wages. The Court of Appeal reversed as to the calculation of unpaid wages (the trial court miscalculated the applicable statute of limitations) and penalties, and in its finding that LaPaille was not personally liable for BPI’s failure to pay. See also Dobarro v. Kim, 116 Cal. App. 5th 158 (2025) (employer’s deadline to appeal Labor Commissioner’s decision was not subject to equitable tolling); Mora v. C.E. Enterprises, Inc., 2025 WL 3214076 (Cal. Ct. App. 2025) (auto dealership did not violate “no borrowing rule” or Cal. Lab. Code § 226.2 vis-à-vis piece-rate compensation paid to its service technicians).