Cal. Codes » Labor Code / DIVISION 2. EMPLOYMENT REGULATION AND SUPERVISION / PART 1. COMPENSATION / CHAPTER 1. Payment of Wages / ARTICLE 1. General Occupations
California Codes

Cal. Labor Code § 222 (2026)

✓ current as of May 2026
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It shall be unlawful, in case of any wage agreement arrived at through collective bargaining, either wilfully or unlawfully or with intent to defraud an employee, a competitor, or any other person, to withhold from said employee any part of the wage agreed upon.

Notes of Decisions
Cited in 17 cases (6 in the last 5 years), 1956–2025 · leading case: Oman v. Delta Air Lines, Inc., 466 P.3d 325 (Cal. 2020).
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Oman v. Delta Air Lines, Inc., 466 P.3d 325 (Cal. 2020). · cites it 2× “Specifically, Labor Code section 221 prohibits an employer from paying wages and then recouping some portion of the wages as a kickback or secret deduction;3 Labor Code section 222 prohibits underpayment of wages established by a collective bargaining agreement;4 and Labor Code…”
Stoetzl v. Dept. of Human Resources, 443 P.3d 924 (Cal. 2019). · cites it 2× “Labor Code section 222 states: "It shall be unlawful, in case of any wage agreement arrived at through collective bargaining, either wilfully or unlawfully or with intent to defraud an employee, a competitor, or any other person, to withhold from said employee any part of the…”
Sarmiento v. Sealy, Inc., 367 F. Supp. 3d 1131 (N.D. Cal. 2019). · cites it 2× “Similarly, Plaintiffs' third claim alleges a violation of California Labor Code section 222, which provides that "[i]t shall be unlawful, in case of any wage agreement arrived at through collective bargaining, either wilfully or unlawfully or with intent to defraud an employee,…”
Gonzalez v. Downtown LA Motors CA2/2, 215 Cal. App. 4th 36 (Cal. Ct. App. 2013). “” Labor Code section 222 provides: “It shall be unlawful, in case of any wage agreement arrived at through collective bargaining, either willfully or unlawfully or with intent to defraud an employee, a competitor, or any other person, to withhold from said employee any part of…”
Skillin v. Rady Child.'s Hosp.-San Diego, 226 Cal. Rptr. 3d 505 (Cal. Ct. App. 5th 2017). “" ( Lab. Code, §§ 222, 224.) Likewise, an employer may not "secretly pay a lower wage while purporting to pay the wage designated by [the applicable] statute or contract.”
Fitz-Gerald v. Skywest Airlines, Inc., 182 L.R.R.M. (BNA) 2839 (Cal. Ct. App. 2007). “2 Labor Code section 222 provides: “It shall be unlawful, in case of any wage agreement arrived at through collective bargaining, either wilfully or unlawfully or with intent to defraud an employee, .”
Local 659, I.A.T.S.E. v. Color Corp. of Am., 302 P.2d 294 (Cal. 1956). “” (Lab. Code, § 222.) A violation of the section is a misdemeanor.”
Thornton v. Victor Meat Co., 68 L.R.R.M. (BNA) 2149 (Cal. Ct. App. 1968). “2d 932 ]; Lab. Code, §§ 222, 223, 225 and 227); and that such right as accrued prior to the termination of the collective bargaining contract can be enforced.”
Columbus Bingham IV v. Padres, L.P. (S.D. Cal. 2025). · cites it 4× “26, 2024) (“Like California Labor Code §§ 222–23, the state statute at issue in 18 Schurke expressly relied upon the terms established by CBAs.”
DeMattio v. SolarCity Corp. CA2/5 (Cal. Ct. App. 2016). · cites it 2× “A fair reading of plaintiffs’ motion for class certification, however, demonstrates that plaintiffs’ primary focus was on the unconscionability of the 8 Labor Code sections 222 and 223 do not appear to apply to the facts of this case.”
Skillin v. Rady Child.'s Hosp.-San Diego (Cal. Ct. App. 2017). “" (Lab. Code, §§ 222, 224.) Likewise, an employer may not "secretly pay a lower wage while purporting to pay the wage designated by [the applicable] statute or contract.”
Jesus Sarmiento v. Sealy, Inc. (9th Cir. 2022). “Defendants carried their burden by showing that Plaintiffs lacked evidence of willful or secret wage deductions. At that point, the burden shifted to Plaintiffs to produce or identify evidence of willful or secret wage deduction.”
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