With Lauren Howard
In its recent decision of Martinez v. Combs, Opinion No. S121522 (May 20, 2010), the California Supreme Court addressed an issue that has gone unresolved for many years: whether an employment relationship exists by virtue of the Industrial Welfare Commission's (IWC) wage orders' definition of "employer," and, therefore, who may be liable for violating California Labor Code section 1194, which allows a civil suit for recovery of minimum or overtime wages due.