What is the effect of section 970 of the California Labor Code on a claim brought by a former employee who was conned into entering into a fraudulent employment contract?

MultiRegion, United States of America

The following excerpt is from Keenan v. Cox Commc'ns Cal., LLC, Case No.: 18cv129-MMA (LL) (S.D. Cal. 2019):

With respect to the nature of the cause of action, even if Labor Code section 970 sounds in common law fraud, it is a separate statutory creation that applies to a specific type of misrepresentation that the California legislature determined to be particularly odious and therefore worthy of a specific penalty. See Mercuro v. Superior Court, 96 Cal. App. 4th 167, 180 (2002) ("Labor Code section 970 also has a public purpose: to protect the community from the harm inflicted when a fraudulently induced employment ceases and the former employee is left in the community without roots or resources and becomes a charge on the community."). To give section 970 teeth, the California legislature promulgated section 972 and its double damages provision. This goes beyond

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