Can an employer be held liable for failing to provide a proper and accurate wage statement to employees?

California Labor Code 226 requires "employers [to] provide accurate itemized statements of wages to their employees" that contain certain statutorily mandated information. Morgan v. United Retail Inc., 186 Cal. App.4th 1136, 1143 (2010). However, an employer is only liable for damages as a result of failing to furnish conforming wage statements to employees that "suffer[ ] injury as a result of a knowing and intentional failure by an employer to

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comply with [section 226(a) ]." Cal. Lab. Code 226(e). Therefore, "a plaintiff must establish two elements to recover damages under section 226:(1) that a defendant's wage statements violated one of the enumerated requirements in section 226(a), and (2) that the violation was 'knowing and intentional' and resulted in 'injury' to the plaintiff." Alonzo v. Maximus, Inc., 832 F. Supp.2d 1122, 1134 (C.D. Cal. 2011) (emphasis in original).