What are the consequences of an employer's refusal to pay an employee's wages?

employee to continue to accrue wages "from the due date thereof" for up to 30 days "until paid or until an action therefor is commenced." Cal. Lab. Code 203(a). Penalties are assigned where an employer "willfully fails to pay." Id. (emphasis added). The meaning of "willful" under 203 "is that an employer has intentionally failed or refused to perform an act which was required to be done." See Amaral v. Cintas Corp. No. 2, 163 Cal. App. 4th 1157, 1201 (2008). "[T]he employer's refusal to pay need not be based on a deliberate evil purpose to defraud workmen of wages which the employer knows to be due." Id. (citation and quotation omitted). Upon discharge, the employee's earned and unpaid wages are due within 72 hours. Id. 201(a).