What are the consequences of an employer's failure to pay the wages of an employee who quits?

Under California law, "[i]f an employer discharges an employee, the wages earned and unpaid at the time of discharge are due and payable immediately." Cal. Lab. Code 201(a). Under section 203, "[i]f an employer willfully fails to pay . . . any wages of an employee who is discharged or who quits, the wages of the employee shall continue as a penalty . . . but the wages shall not continue for more than 30 days." Id. 203(a). In the context of section 203, "willful" has been defined as an employer "intentionally fail[ing] or refus[ing] to perform an act which was required to be done." Amaral v. Cintas Corp. No. 2, 163 Cal. App. 4th 1157, 1201 (2008) (citing Barnhill v.

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