On February 26, 2025, in Parra Rodriguez v. Packers Sanitation, Inc., the California Court of Appeal (Fourth Appellate District) issued the latest published decision addressing the practice of filing so-called “headless” Private Attorneys General Act (PAGA) claims. In such cases, the plaintiff seeks civil penalties for all allegedly aggrieved employees except themself. In the wake of Viking River Cruises, Inc. v. Moriana, 596
California Labor Code

Chamber of Commerce Challenges California Ban on “Captive Audience” Meetings
As we reported here, California’s Senate Bill (S.B.) 399, took effect on January 1, 2025. This law prohibits employers from requiring employees to attend meetings about the company’s opinions on political or religious matters, including discussions about unionization. California joins almost a dozen other states, including Illinois, New York, and Oregon, in enacting union-backed statutes that prohibit so-called “captive audience” meetings.
The Teamsters…
California Updates Paid Sick Leave FAQs: What Employers Need to Know

The California Department of Industrial Relations (DIR) has released updated guidance clarifying how the state’s latest statutory enactments will impact employers’ paid sick leave obligations. Specifically, as we reported here, Assembly Bill (AB) 2499 and Senate Bill (SB) 1105 expand the permissible reasons for which employees can use paid sick leave.
The updated FAQs now explain that, in addition to existing uses of paid…
A Glimmer of Hope for Employers Defending Against PAGA Claims

The future of PAGA continues to look a bit brighter for employers as new favorable case law emerges. We previously reported on Turrieta v. Lyft, Inc. wherein the California Supreme Court ruled that PAGA plaintiffs have no standing to intervene in parallel PAGA lawsuits. We are now happy to report that another “win” for employers has come out of Second Appellate District of the Los…
Hot PAGA Summer Rolls on with Another “Win” for Employers

The “Summer of PAGA” continued last week when the California Supreme Court ruled in Turrieta v. Lyft, Inc., Case No. S271721, that a plaintiff in a Private Attorneys General Act (PAGA) action does not have standing to intervene or object to a settlement in a parallel action involving overlapping PAGA claims.
The structure of PAGA tends to invite the scenario facing the parties and…
PAGA 2.0 – Early Evaluation Conferences May Help Defendants Cut to the Chase

On June 27, 2024, the California Legislature passed AB 2288 and SB 92, compromise legislation that reformed the Private Attorneys General Act (PAGA) and averted a ballot measure that threatened to repeal the law entirely this November. We previously reported on the compromise here when the deal was announced, and published a primer on the substantive changes to the law here.
Arguably the…
PAGA 2.0 – What Employers Need to Know As PAGA Reform Becomes Law

On June 27, 2024, by near-unanimous vote, the California Legislature passed two bills enacting much-needed reform to the Private Attorneys General Act (PAGA). We previously reported on the legislative compromise last week, when the deal was first announced.
The most profound changes are contained in AB 2288, which amended Labor Code § 2699—the beating heart of PAGA. AB 2288 makes several significant changes to the…
January 2024 California Employment Law Notes
We invite you to review our newly-posted January 2024 California Employment Law Notes, a comprehensive review of the latest and most significant developments in California employment law. The highlights include:
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Trial Court Gave Erroneous Jury Instructions In Whistleblower Case
Garrabrants v. Erhart, 2023 WL 9016436 (Cal. Ct. App. 2023)
Charles Matthew Erhart was an internal auditor for a financial institution who “blew the whistle” on the employer concerning the actions of the bank’s CEO, Gregory Garrabrants. While Erhart’s whistleblower case was pending in federal court, Garrabrants sued Erhart in state court for copying, retaining and transmitting to multiple regulatory authorities documents Erhart believed…
November 2023 California Employment Law Notes
We invite you to review our newly-posted November 2023 California Employment Law Notes, a comprehensive review of the latest and most significant developments in California employment law. The highlights include:
- Company That Hired Competitor’s Employee Was Not Entitled To Arbitrate Claims
- Disability Discrimination Claim Was Properly Dismissed On Summary Judgment
- Employee’s Attorney’s “Pervasive Incivility” Justified $460,000 Reduction In Fees
- Employees Were Properly Awarded $7.2 Million
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