In Estrada v. Royalty Carpet Mills, Inc., 76 Cal. App. 5th 685 (2022), the California Court of Appeal, in relevant part, reversed a trial court’s order decertifying a subclass and dismissing related Private Attorneys General Act (PAGA) claims as unmanageable. In doing so, the court held “a court cannot strike a PAGA claim based on manageability.”
Plaintiffs, employees at carpet manufacturing facilities, brought an action against their employer alleging representative claims under the PAGA and class claims for purported meal and rest period violations, derivative claims for wage statement and waiting time penalties and violation of the Unfair Competition Law, and a claim for declaratory relief. The trial court initially certified two classes (i.e., one class of workers in Porterville, California and a second class of workers in Dyer and Derian, California) with multiple subclasses. After trial, the court, in relevant part, decertified the Dyer/Derian meal period subclass because there were too many individualized issues to support class treatment and then dismissed the portion of the PAGA claim based on meal period violations at Dyer/Derian “because the individualized issues made it unmanageable.”
The Court of Appeal for the Fourth District reversed, in relevant part, finding that the trial court improperly dismissed the PAGA claim as unmanageable. In doing so, the court expressly stated that the purpose of publishing its opinion was to discuss concerns...
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