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

Turrieta v. Lyft, Inc., 16 Cal. 5th 664 (2024)

This case involved “what has become a common scenario in PAGA litigation” in which multiple persons claiming to be an “aggrieved employee” within the meaning of the Private Attorneys General Act of 2004 (PAGA) file separate and independent lawsuits seeking recovery of civil penalties from the same employer for the same alleged Labor Code

Ibarra v. Chuy & Sons Labor, Inc., 102 Cal. App. 5th 874 (2024)

The trial court dismissed Edelmira Ibarra’s action under the Private Attorneys General Act of 2004 (“PAGA”) on the ground that Ibarra failed to comply with PAGA’s prefiling notice requirements.  Ibarra’s notice identified four named defendants who employed Ibarra from January 2021 to July 2021 and alleged that all four defendants committed

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

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

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

Balderas v. Fresh Start Harvesting, Inc., 101 Cal. App. 5th 533 (2024)

Lizbeth Balderas sued her former employer on behalf of 500 other current and former employees of an agricultural company, seeking civil penalties under the California Labor Code Private Attorneys General Act of 2004 (“PAGA”).  In her complaint, Balderas stated she was “not suing in her individual capacity; she is proceeding herein solely under

The California Supreme Court has issued its much-anticipated decision in Estrada v. Royalty Carpet Mills, Inc., determining whether Private Attorneys General Act (PAGA) claims can be dismissed as unmanageable.  The Court affirmed a lower court’s decision, holding that “trial courts lack inherent authority to strike PAGA claims on manageability grounds”—that is, trial courts may not “dismiss [them] with prejudice.”  Slip op. at 1-2.  In