Confronted with the question of whether failure to pay regular and overtime wages, failure to pay minimum wage, and pay stub irregularities could support an award for punitive damages, the California Court of Appeal, in Brewer v. Premier Golf Properties, LP, held that such wage and hour statutory violations could not support a punitive damages award. This decision eliminates uncertainty as to the scope of available remedies in wage and hour cases -- at least as the uncertainty pertains to possible punitive damages. Unless the California Supreme Court grants a petition for review, this decision will mean that California employers can address statutory wage and hour claims without the prospect of punitive damages awards.