In California, there has long been the sacred principle that employers cannot recover those wages actually earned by employees. But rules are made to be broken. In a recent ruling, an employer received a damages award based on salary and benefits paid to an employee who breached his fiduciary duties by secretly competing with his employer. Service Employees Internat. Union, Local 250 v. Colcord, 160 Cal. App. 4th 362 (2008). This case emphasizes that a disloyal employee cannot benefit from his or her disloyalty because of the undivided loyalty owed by an employee to an employer.