Topics: Court Decisions, PAGA
In a decision with important implications for many pending Private Attorneys General Act (PAGA) lawsuits, a California Court of Appeal upheld the dismissal of a representative PAGA action as untimely because the plaintiff did not submit a PAGA notice letter within one year of their last day of employment. The court’s decision in Williams v. Alacrity Solutions Group, LLC, which was published on April 22, 2025, holds that PAGA plaintiffs “must, among other things, seek to recover civil penalties on [their] own behalf … and must establish that [their] so-called ‘individual claim’ is timely as to at least one Labor Code violation.”
While this decision is consistent with the presently operative PAGA provisions, effective July 1, 2024, the Williams v. Alacrity case is governed by the PAGA statutes in effect before the amendments. Nonetheless, the appellate court concluded that the amendments simply made “the already-existing timeliness requirement explicit within PAGA itself.”
Notably, the appellate court adopted the reasoning in Leeper v. Shipt, Inc., which, as discussed in our recent blog post, was recently taken under review by the Cal. Supreme Court. Such reliance is unsurprising because both decisions, Williams v. Alacrity and Leeper v. Shipt, were decided by the California Court of Appeal for the Second Appellate District.
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