Estrada v. Royalty Carpet Mills, Inc., 76 Cal. App. 5th 685 (2022)

In this PAGA case, the trial court relied upon Wesson v. Staples the Office Superstore, LLC, 68 Cal. App. 5th 746 (2021) in which the Court of Appeal held that trial courts have inherent authority to strike unmanageable PAGA claims. The Court of Appeal in this case reversed the dismissal based upon unmanageability grounds, holding that “[a]llowing dismissal of unmanageable PAGA claims would effectively graft a class action requirement onto PAGA claims, undermining a core principle” established in at least two prior California Supreme Court cases. The Court further noted that

…courts are not powerless when facing unwieldy PAGA claims. Courts may still, where appropriate and within reason, limit the amount of evidence PAGA plaintiffs may introduce at trial to prove alleged violations to other unrepresented employees. If plaintiffs are unable to show widespread violations in an efficient and reasonable manner, that will just reduce the amount of penalties awarded rather than lead to dismissal.

The Court also held that certain releases in settlement agreements that the employer negotiated with individual class members prior to trial were valid; the trial court correctly applied a seven percent prejudgment interest rate to premium pay awarded under Lab. Code § 226.7 rather than a 10 percent rate; and the employer was entitled to judgment on certain derivative waiting time and wage statement claims. However, the trial court erred in failing to find that a meal period claim, which was added in an amended complaint, did not relate back to a prior complaint and in decertifying a subclass of claims. Finally, the Court held that a meal policy that required employees to remain at the facility during meal breaks violated governing law. See also Shaw v. Superior Court, 2022 WL 1400806 (Cal. Ct. App. 2022) (trial court properly applied the exclusive concurrent jurisdiction rule to later-filed PAGA action involving claims that overlapped with earlier-filed action).