The California Supreme Court's decision in Arias v. Superior Court has profound implications on California's employment market and economy. Currently, two related enemies lay siege on California, threatening not only the state's future prosperity, but perhaps overall survival. The first aggressor, spearheading the attack, is the state's enormous budget deficit. Once touted as the world's eighth largest economy, California now faces a sixty billion dollar budget crisis and a series of tax hikes and spending cuts that only further endanger the people. The other, less recognizable aggressor is California's thriving underground economy. Mainly comprised of businesses that exploit the constant growth of California's workforce to violate wage and hour laws, the underground economy is responsible for tax evasion, unfair competition, business failures, job losses, and unsafe working conditions. This threat, though less recognizable than the budget deficit, is arguably more lethal; after all, it is at least partially responsible for the budget deficit's birth. Then, once the budget deficit arrives to terrorize California and its citizens, margins tighten and more businesses need to violate wage and hour laws to compete. This frustrates California's efforts to erase the budget deficit. Anyway, regardless of which threat is more striking, taken together, the underground economy and budget deficit are so toxic that some observers rename the Golden State America's first failed state.