Cal-Peculiarities: How California Employment Law is Different 2022 Edition

152 | 2022 Cal-Peculiarities ©2022 Seyfarth Shaw LLP  www.seyfarth.com 503 Voris v. Lampert , 7 Cal. 5th 1141, 1156-58 (2019) (claims for unpaid wages resemble other actions for particular amounts of money owed in exchange for contractual performance—a type of claim that has long been understood to sound in contract, rather than as the tort of conversion). 504 Id . at 1163-70. 505 Lacagnina v. Comprehend Sys., Inc. , 25 Cal. App. 5th 955, 972 (2018) (sustaining grant of nonsuit against “wage theft” claim under Penal Code section 496(c): “If every plaintiff in an employment or contract dispute could also seek treble damages and attorneys’ fees on the ground that the defendant received ‘stolen property,’ such claims would become the rule rather than the exception, parties would more frequently assert claims for ‘theft’ in run-of-the-mill commercial disputes, and cases would be harder to settle. We cannot believe the Legislature contemplated, much less intended, those consequences when it enacted section 496, subdivision (c).”).