- High-Frequency and Vexatious Filers: § 17415(a)(2) addresses “documented instances of some attorneys filing PAGA notices that are based on
Settlement
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…
Non-Party Plaintiffs With Overlapping PAGA Claims May Be Able To “Permissibly Intervene” In Related Actions
Accurso v. In-N-Out Burgers, 2023 WL 5543525 (Cal. Ct. App. 2023)
Plaintiffs Tom Piplack and Brianna Marie Taylor filed PAGA actions in Orange and Los Angeles Counties, respectively, against respondent In-N-Out Burgers (In-N-Out). When they learned about settlement negotiations in a later, overlapping PAGA action brought by Ryan Accurso against In-N-Out in Sonoma County, Piplack and Taylor filed a proposed complaint to intervene in…
November 2022 California Employment Law Notes
We invite you to review our newly-posted November 2022 California Employment Law Notes, a comprehensive review of the latest and most significant developments in California employment law. The highlights include:
- Equal Pay Act Claim Should Not Have Been Dismissed
- Whistleblower Claim Should Not Have Been Dismissed In Part
- School District Employee May Have Been Discriminated Against On The Basis Of A Disability
- Offer To
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Offer To Settle Expired When The Court Granted Summary Judgment Motion
Trujillo v. City of Los Angeles, 2022 WL 15119812 (Cal. Ct. App. 2022)
In a negligence case, the City of Los Angeles made a settlement offer to the plaintiff pursuant to Cal. Code Civ. Proc. § 998 a few days before the hearing on defendant’s motion for summary judgment. Just four minutes after the court granted defendant’s summary judgment motion, plaintiff’s counsel emailed a…
May 2022 California Employment Law Notes
We invite you to review our newly-posted May 2022 California Employment Law Notes, a comprehensive review of the latest and most significant developments in California employment law. The highlights include:
- Former UCLA Physician Can Proceed With Whistleblower Claims
- Former Employee Adequately Alleged Disability Under The ADA
- California Resident May Rely Upon Labor Code § 925 To Challenge Non-Compete
- School District Is Not Liable For
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Trial Court Should Not Have Dismissed PAGA Claims On Unmanageability Grounds
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…
March 2022 California Employment Law Notes
We invite you to review our newly-posted March 2022 California Employment Law Notes, a comprehensive review of the latest and most significant developments in California employment law. The highlights include:
- California Relaxes Standard For Proving Whistleblower Claims
- At-Will Employee Can Proceed With Labor Code § 970 Claim
- Doctor Proved Age/Race/Gender Discrimination
- Former Owner of Company Is Enjoined From Soliciting Customers
- OSHA’s COVID-19 Vaccine Mandate
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Heightened Standard Of Fairness Required For Approval Of Class Action Settlement
Peck v. Swift Transp. Co. of Ariz., 2022 WL 414692 (9th Cir. 2022)
In evaluating a settlement of a class action involving Cal. Labor Code § 2802 (employer indemnity for employee expenses), the district court stated that “the parties engaged in arm’s-length, serious, informed and non-collusive negotiations between experienced and knowledgeable counsel … after mediation with a neutral mediator. The settlement agreement is therefore…
January 2022 California Employment Law Notes
We invite you to review our newly-posted January 2022 California Employment Law Notes, a comprehensive review of the latest and most significant developments in California employment law. The highlights include:
- Manicurist Can Proceed With Hostile Work Environment Claim
- “Volunteers for Nonprofits Are Not Employees” – Court Affirms Order In Favor Of The American Film Institute
- Nurse’s Discrimination Claims Against Hospital Were Properly Dismissed
- Security
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