Disagreeing with Villacorta v. Cemex Cement, Inc. (2013) 221 Cal.App.4th 1425, this decision holds that income a wrongfully terminated employee earns from another job after termination must be subtracted from her past economic damages for the wrongful termination whether or not the subsequent employment was not comparable or substantially similar to the job that was wrongfully terminated. The comparable or substantially similar qualification applies when the employer raises a mitigation of damages defense, claiming that the former employee should have (but did not) obtain other available employment. That qualification does not apply when the former employee actually accepts other employment and earns income. Actual earnings from substitute employment are offset from lost earnings awards regardless.