Trial courts in California can no longer discard lawsuits brought under the state’s Private Attorneys General Act (PAGA) over concerns that they would be unmanageable to try in court, following a ruling from the California Supreme Court.
The court’s decision in Estrada v. Royalty Carpet Mills is “going to embolden the plaintiff’s bar,” and it’s going to make settlements much more difficult, said Andrew Paley, an attorney with Seyfarth in Los Angeles. As a result of the ruling announced Jan. 18, “there’s going to be a tremendous amount of litigation and frankly confusion at the trial court level.”
[See related article, “The Three Biggest PAGA Questions California Employers Have for 2023”]
Most PAGA claims deal with labor violations like unpaid wages or missed meal breaks. They can be an individual claim or a class-action claim. To determine manageability, courts consider whether issues pertaining to individual class members may be fairly and efficiently adjudicated.
In Estrada, a group of employees sued a carpet manufacturer with worksites in Santa Ana and Irvine, Calif., claiming it failed to provide required meal breaks. A trial court dismissed the case as being unmanageable. An appeals court reversed the trial court’s decision, allowing the case to proceed. The company claimed that allowing the case to go forward violated its due process rights and argued that trial courts can strike claims to preserve judicial resources and prevent trials from becoming excessively...
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