Williams v. Alacrity Solutions Grp., LLC, 110 Cal. App. 5th 932 (2025)

Corbin Williams sued his former employer (Alacrity Solutions Group, LLC) for various wage and hour violations. However, Williams failed to provide written notice of his claims to the state Labor & Workforce Development Agency (LWDA) until more than a year had passed since the end of his employment with Alacrity, thus barring any individual claims he may have had under the Private Attorneys General Act (PAGA). Williams subsequently filed a PAGA claim only on behalf of “other current and former employees” but, according to the Court of Appeal, “critically, not on his own behalf.” Alacrity filed a demurrer in response to the complaint on the ground that the purported representative action that Williams asserted was barred by the one-year statute of limitations in that he lacked standing to assert any claim (individual or representative) under the statute. The trial court sustained the demurrer to the complaint without leave to amend. The Court of Appeal affirmed the dismissal. Other recent PAGA developments: Moniz v. Adecco USA, Inc., 109 Cal. App. 5th 317 (2025) (plaintiff in parallel PAGA action lacks standing to challenge settlement of another employee’s PAGA suit (citing Turrieta v. Lyft, Inc., 16 Cal. 5th 664 (2024)); Rose v. Hobby Lobby Stores, Inc. 2025 WL 1392271 (Cal. Ct. App. 2025) (prevailing party employer may not recover its costs from LWDA, which was not a party to the action); Chavez v. Hi-Grade Materials Co., 2025 WL 1231999 (Cal. Ct. App. 2025) (putative class action plaintiff cannot “ring the death knell” for the entire class by voluntarily dismissing all remaining representative claims after class certification has been denied).