This Law Firm Publication by Fisher & Phillips LLP discusses the California Supreme Court's recent decision in Salas v. Sierra Chemical Co. In this case, Salas, who was laid off after filing a workers' compensation claim, sued for failure to accommodate his disability and retaliation. Right before trial, Sierra learned that Salas was not authorized to work in the US and had provided a false social security number and resident alien card. Sierra moved to dismiss the case based on Salas's unclean hands relying on the after-acquired evidence defense. Sierra showed it had a long-standing policy against hiring unauthorized workers and the Court of Appeal found in its favor. The California Supreme Court reversed, concluding that where an employee misrepresents his employment authorization, the federal Immigration Reform and Control Act (IRCA) does not preempt California's anti-discrimination law, which states that its protections are available to all regardless of immigration status. The Supreme Court held, however, that Salas may not recover lost wages for the period after Sierra discovered his misrepresentations because IRCA prohibits an employer from continuing to employ a worker it knows is unauthorized. The Court also suggested that particularly egregious conduct may limit recovery further.