California Court Confirms Wages Due on Weekends May Be Paid Next Day

06/12/2023

By: HR NETwork Inc

HR NETwork

We Put the Human Back
In Human Resources

The California Supreme Court recently confirmed that California Labor Code Section 204 requires employees to be paid on weekends.

In the case Parsons v. Estenson Logistics, an employee sought to pursue claims under California’s Private Attorneys General Act (PAGA), alleging he was consistently paid two days late each week because his employer paid wages due on Saturday on the following Monday, which violated California Labor Code section 204, requiring that weekly-paid employees get paid within seven calendar days after the end of each weekly payroll period.

The Company used a standard Sunday-through-Saturday workweek and paid its California employees every week, meaning the seventh day following a workweek fell on Saturday. Because the Company’s administrative offices were closed, and banks were not open on weekends, the company issued paychecks the following Monday.

The Company argued that this schedule is consistent with the State of California’s longstanding position on the subject. The Division of Labor Standards Enforcement’s (DLSE) published guidelines have explained for nearly 20 years that wages due on a weekend or holiday may be paid on the next business day.

A trial court judge held that, while the DLSE Manual is not binding on the court, it is a reasonable interpretation of California’s law. On appeal, the Third District Court of Appeal also sided with the Company, but stated that it “cannot … adopt an interpretation of section 204(d) that wholly ignores section 12a, and must instead adopt an interpretation that gives effect to both.” Since 12a extends deadlines for “all … provisions of law,” the deadline to pay wages may also be extended.

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The published Third District Court of Appeal decision means that wages that would be due on a weekend under California labor law may be paid on the next day that is not a weekend or holiday (i.e., the next Monday, or the next Tuesday if that Monday is a state-recognized holiday).

While this previously was how the law was being interpreted and applied, it was technically an unanswered question of law. The decision by the Third District Court of Appeal now provides clear guidance for all California employers that wage payment deadlines follow the same procedural rules as any other legal deadline.

Genoveva Godoy-Thomas

Genoveva Godoy-Thomas joined HR NETwork in October of 2022. She was born in Guatemala, spent her formative years in Fairfax, Virginia and spent over 20 years living in Bethesda, Maryland. As a teen she spent her summers in Orange County where she currently resides. She has native fluency in both English and Spanish.

A seasoned human resource professional, having worked at Marriott International for 23 years in various Human Resources related roles in addition to working as a Human Resources manager/office manager for an Estate planning firm. She also holds a B.S. in Business Management and Human Resources Management from the University of Maryland.

Genoveva enjoys volunteering at First Tee golf photographing events, actively volunteering at her son and nieces’ school when needed. She loves to spend her time with her son enjoying the outdoors and teaching him to love and respect nature. 

Michelle Brubaker

Michelle Brubaker, the Business Manager of HR NETwork, has been with the company for 16 years. Joining the team as an HR Coordinator, she quickly worked her way up to Executive Assistant and on to her current role as Business Manager. Handling all things business-related including contracts and accounting, she is the unwavering support of HR NETwork.


Michelle has an impressive resume with almost 20 years of experience in supervising, managing, and motivating teams. Her strengths lie in building trust with her colleagues and clients, delivering results, and creating efficient processes to align with the company’s mission. Her passion and dedication have made her an integral part of the business.

She believes our clients are an extension of the HR NETwork family and genuinely loves assisting them. “It’s a great feeling knowing during critical times, we are able to put their minds at ease and hold their hands through them”.

Outside of work, Michelle enjoys travelling, country music and all things self-development. She has a fur baby named Buddy and loves being outdoors with him as well.

Shannon Martin

Shannon Martin, Senior Human Resource Professional brings over thirty years of human resources experience and expertise from Fortune 500 high-technology and service companies. Shannon has held both HR leadership and consulting roles. She has supported clients across a variety of industries including fiduciary services and investment management, consumer and real estate information, health care, beauty, and a large IT Infrastructure group.

Her scope of experience is broad and progressive and the disciplines she finds to be most rewarding are: Strategic Planning, Organizational Development Leadership Development, Change Management, Performance Management Coaching and Mediation & Conflict Resolution. 

Shannon has “hands-on” experience implementing mergers and acquisitions and building HR Departments. She has completed extensive coursework in communication and excels at building organizational processes that bring cohesion and engagement. She enjoys motivating and mentoring employees to help them achieve increased business performance.  

Shannon holds a Human Resource Management Certificate from UC Irvine.  She is a certified Senior Professional in Human Resources (SPHR).

Shannon considers herself an HR geek and finds reward when solving a challenge creatively. Shannon earned the Radio Rookie of The Year Award from KBPK, a college station. She also earned the Leadership Award presented by First American Trust Company. A cowgirl at heart, she loves being outside and working with animals of any kind.

Michelle Odell

Michelle Odell is currently a Talent Acquisition and Human Resources Manager with HR Network and has experience ranging from Recruiting, General HR, Employee Relations and Training.  She enjoys helping employees navigate through questions they may have with career development, understanding benefits, policies, or recruitment. 

Michelle has a Bachelor’s degree from California State University, Fullerton and majored in Psychology with an emphasis in Human Resources.  She spent some time away from HR Network to recruit for a company bringing them from 5 to 130+ employees.  She was happy to return to HR Network in 2019 and is enjoying being part of the team and learning about new laws and practices. 

Michelle was born and raised in California and has three children, three cats, two dogs, a McCaw, and a husband

Lee Anne Woods

The newest member of our team, Lee Anne Woods is an HR Administrator and has been with HR NETwork for 4 months. She previously worked in Human Resources in the mortgage and banking field, as well as doing secondary marketing for 10 years. Lee Anne decided to join HR NETwork when she realized how rewarding it is to be able to help clients navigate the crazy world of HR! “What I like about HR NETwork is how much we care about our clients, and how much we value learning and growing, so we may give them the most up to date information and trends out there!”

Lee Anne has a husband and two grown daughters. She enjoys travelling around the country and watching her daughters sporting events!

Lorraine Calder

Lorraine Calder has been an HR Manager at HR NETwork for 12 years. Since making a major movie from the UK to the US in 1997, she has enjoyed keeping up with the everchanging CA labor laws. She believes knowledge is a powerful tool to have, and is always happy to share her knowledge and experiences with our clients, along with the many HR trainings we provide. As a people person, Lorraine really enjoys making relationships with our clients, and is happy that our clients and vendors put their trust and confidence in our team. She gets great satisfaction at the end of the workday, knowing that she has achieved something special and values being part of a great and caring team!

Lorraine enjoys spending time with her three grandsons and two granddaughters. “Nothing is impossible if you set your mind to it, I am living proof of that.”

Michelle Espinoza

Michelle Espinoza joined the HR NETwork team in 2014 in the capacity of HR Manager and has more than 10 years of progressive management experience in human resources. She is now the senior HR Manager at HR NETwork and leads the HR management team in supporting our clients. 

Her career began in Talent Acquisition where she acquired a strong aptitude in employee relations.  She realized that a lot of companies needed help in navigating through the endless California employment laws and legislation. This led her to transition to Human Resources to focus on helping companies maintain legal compliance.  

Michelle has a keen understanding that business processes are vitally important to any business sector and apply to all types of organizations.  Realizing that the commonality amongst various industries generally results in the same matters led Michelle to what she truly enjoys – strengthening the partnership with our clients in HR matters.  

Michelle holds a B.S in Business Management with an emphasis in Human Resources.  

During her free time, she enjoys fitness, outdoor activities, spending time with family and friends.