California Labor Code Definition of "Discharge"
A woman who worked as a hair model at a L'Oreal show earned $500 for her day of work, but did not receive the money until two months after the show. She sued on behalf of herself and other models for failure to pay wages immediately upon discharge in violation of Labor Code § 201, and sought $15,000 in penalties under Labor Code § 203. The trial court granted L'Oreal's motion for summary judgment and the court of appeal denied Plaintiff's petition for writ of mandate. The California Supreme Court reversed and remanded, holding that the definition of "discharge" under the statute is not limited to termination, and may also apply when an employer releases an employee after completion of a specific job assignment or time duration. Between this and the Yanowitz decision, not a good year for L'Oreal, from a Supreme Court litigation standpoint. Smith v. Superior Court (L'Oreal USA, Inc.), 2006 DJDAR 8988 (July 10, 2006)