Rodriguez v. Lawrence Eqpt., Inc., 2024 WL 4719479 (Cal. Ct. App. 2024)

Julian Rodriguez sued his former employer, Lawrence Equipment, Inc., for various wage and hour violations under the Labor Code and sought civil penalties and wages pursuant to the Private Attorneys General Act (PAGA). Enforcing the arbitration agreement Rodriguez had signed, the trial court ordered arbitration of the wage and hour claims and stayed Rodriguez’s single PAGA cause of action pending the arbitration. After the arbitrator found in favor of Lawrence and against Rodriguez on the alleged wage and hour claims, Lawrence brought a motion for judgment on the pleadings in the trial court, asserting that the PAGA action was barred by issue preclusion because Rodriguez’s standing as an aggrieved employee was based on the disproven wage and hour violations. The trial court granted the motion and dismissed the case. The Court of Appeal affirmed, holding that all of the elements of issue preclusion were satisfied and, therefore, Rodriguez was precluded from litigating the alleged Labor Code violations in an attempt to establish that he is an aggrieved employee under the PAGA statute.