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Coma Corporation v. Kansas Department of Labor

Citation. 154 P.3d 1080 (Kan. 2007)
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Brief Fact Summary.

The Coma Corporation (Coma) sought federal review of a Kansas Department of Labor decision that required Coma to pay unpaid wages to a terminated, undocumented worker.

Synopsis of Rule of Law.

An employer cannot avoid compensating an undocumented worker using the illegality defense.


Coma Corporation (Coma) fired Cesar Martinez Corral (Corral) and Corral sued for unpaid wages under the Kansas Department of Labor (KDOL). The KDOL hearing awarded Corral unpaid wages including interest and Coma sought federal review of the KDOL decision. The district court only entitled Corral to minimum wage with no penalty because Corral was undocumented. KDOL appealed.


Whether an employer can avoid compensating an undocumented worker using the illegality defense?


No. The Kansas Wage Protection Act (KWPA) does not exclude undocumented workers from the benefits of employees. Similarly, federal courts provide protection to undocumented workers in federal labor laws. The KWPA therefore furthers the initiatives of the IRCA. The district court improperly found that Coma could avoid paying damages for breach of contract, and the imposition of penalties from the KDOL is affirmed. AThe judgment of the district court is affirmed in part and reversed in part.


The Immigration Reform and Control Act (IRCA) prohibits the employment of undocumented workers and deems any illegal contract void. However, if the employer willingly enters into an illegal contract, the employer is not allowed to benefit from the contract at the expense of the employee.

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