In McCoy v. Superior Court, the California court of appeal held that claims to recover California Labor Code waiting time penalties are subject to a one-year statute of limitation. Plaintiff brought a class-action lawsuit against a provider of temporary employees, alleging that the employer failed to timely pay final wages on completion of temporary work assignments. Although the employer had paid all wages owed, plaintiff sought penalties for late payments. The court ruled that plaintiff was limited to seeking penalties for the one-year period before the lawsuit was filed.