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As a matter of law, Plaintiffs’ cannot recovery punitive damages for Labor Code violations. Brewer v. Premier Golf Properties (2008) 168 Cal.App.4th 1243, 1252. In Brewer, the court stated:

We are convinced, both by application of the “new right-exclusive remedy” doctrine and under more general principles that bar punitive damages awards absent breach of

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California law has held that “employer” does not include an entity’s agents, and therefore there is no personal liability for Labor Code violations. Reynolds v. Bement (2005) 36 Cal.4th 1075, 1087-88; Jones v. Gregory (2006) 137 Cal.App.4th 798, 805. The California Supreme Court explained in Reynolds that under common law, corporate agents are not personally…