A California Court of Appeal recently held that an employee bringing a claim under the Private Attorneys General Act (PAGA) must be able to allege that he personally suffered a Labor Code violation within the applicable one-year statute of limitations period.
Williams v. Alacrity Solutions Group, LLC, 2025 WL 1165248, at *1 (Cal. Ct. App., Apr. 22, 2025, No. B335445). This case furthers the recent trend against “headless” representative PAGA claims.
PAGA lawsuits are governed by a one-year statute of limitations. Corbin Williams filed a PAGA lawsuit against his former employer, Alacrity Solutions Group, LLC, more than one year after he had left employment. Recognizing that any individual claim for PAGA penalties he might have would be “time-barred,” Williams purported to file his complaint solely in a representative capacity to obtain PAGA penalties on behalf of others.
Alacrity challenged the complaint, arguing that Williams’s complaint should be dismissed because his individual PAGA claim was barred by the one-year statute of limitations and, without an individual claim, he failed to state a valid PAGA cause of action. The trial court agreed with Alacrity and dismissed the case.
On appeal, the court ruled that a PAGA claim necessarily contains both an individual claim and a representative claim, relying on Leeper v. Shipt, Inc., 107 Cal.App.5th 1001 (2024). Moreover, the court held that the employee bringing the lawsuit must be able to set forth a timely individual...
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