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Hernandez v. Ray Domenico Farms, Inc.

Colo.March 5, 2018No. Supreme Court Case 17SA77Cited 21 times
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Case Details

Status — whether other courts must follow this ruling
Published
Procedural Posture — the stage the case had reached
appeal

Related Laws

No specific laws identified for this ruling.

Claim Types

Wage Theft

Outcome

Colorado Supreme Court answered a certified question of law regarding the statute of limitations for wage claims under the Colorado Wage Claim Act. The Court held that terminated employees may seek unpaid wages from throughout their employment, but such claims are subject to a two-year statute of limitations (three years for willful violations) running from when wages first became due and payable, limiting recovery to the two or three years immediately preceding termination.

Excerpt

C.A.R. 21.1— Certified Questions of State Law—Colorado Wage Claim Act—Statute of Limitations—Statutory Construction. The Supreme Court accepted jurisdiction under C.A.R. 21.1 to answer a certified question of law from the U.S. District Court for the District of Colorado regarding how far back in time a terminated employee's unpaid wage claims can reach under the Colorado Wage Claim Act, CRS §§ 8-4-101 to -123. The Court held that, under the plain language of CRS § 8-4-109, a terminated employee may seek any wages or compensation that were unpaid at the time of termination however, the right to seek such wages or compensation is subject to the statute of limitations found in CRS § 8-4-122. That statute of limitations begins to run when the wages or compensation first become due and payable and thus limits a terminated employee to claims for the two years (three for willful violations) immediately preceding termination.

What This Ruling Means

**What Happened** A worker named Hernandez sued Ray Domenico Farms for unpaid wages after being fired. The case reached the Colorado Supreme Court because a federal judge needed clarification on Colorado's wage laws—specifically, how far back in time fired workers can go to collect unpaid wages they're owed. **What the Court Decided** The Colorado Supreme Court ruled that terminated employees can seek unpaid wages from their entire time working for an employer, but there are strict time limits. Workers must file their claims within two years of when the unpaid wages were first due (or three years if the employer willfully violated wage laws). This means workers can typically only recover wages from the two or three years immediately before they were fired, even if they were underpaid for longer. **Why This Matters for Workers** This ruling clarifies an important deadline for Colorado workers pursuing wage theft claims. If you believe your employer owes you money for unpaid wages, overtime, or other compensation, you need to act quickly after being fired. Waiting too long could cost you the right to recover older unpaid wages, even if you have proof your employer cheated you out of money earlier in your employment.

This summary was generated to explain the ruling in plain English and is not legal advice.

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