Williams v. Superior Court, 3 Cal. 5th 531 (2017)

Michael Williams was an employee of Marshalls of CA in Costa Mesa, California. After slightly more than a year of employment, Williams brought a representative action against Marshalls under the Labor Code Private Attorneys General Act of 2004 (“PAGA”), alleging Marshalls had failed to provide its employees with meal and rest breaks, accurate wage statements, reimbursements for necessary business-related expenses and to pay all earned wages during employment. During discovery, Williams served special interrogatories, seeking the names and contact information of all nonexempt Marshalls employees in California who had worked for the company in the previous two years. Marshalls objected, and the trial court ordered Marshalls to produce contact information only for the employees who had worked at the Costa Mesa store, denying contact information for employees who worked at the other 128 Marshalls stores in California. Williams filed an unsuccessful petition for writ of mandate with the Court of Appeal in which he sought to compel the trial court to vacate its discovery order and to enter a new order granting Williams’ motion to compel production of a list of all employees statewide. In this opinion, the California Supreme Court reversed the lower court and held that a litigant in a PAGA lawsuit should be accorded discovery as broad as would be available in a class action.