On 18 January 2024, the Supreme Court of California (Court) unanimously held that trial courts lack inherent authority to dismiss with prejudice claims brought under the Labor Code Private Attorneys General Act of 2004 (PAGA) for lack of manageability.1The Court's conclusion rested primarily on differences in the structure and jurisprudential history of PAGA and class action claims. In addition, the Court concluded that PAGA defendants' due process rights are not violated by virtue of not striking unmanageable PAGA claims before trial.
Conflicting Rulings of Lower Courts
The Estrada decision settled a split of authority among California Courts of Appeal, which disagreed about whether this form of inherent authority existed.2In Wesson, previously discussed here, a California Court of Appeal held that trial courts have inherent authority to ensure that PAGA claims will be manageable at trial and "if necessary, may preclude the use of this procedural device." 3In other words, a trial court has inherent authority to dismiss a PAGA claim with prejudice if it determines that the claim cannot be tried fairly and efficiently.
In Estrada, however, a different California Court of Appeal reached the opposite conclusion, reasoning that "dismissal of unmanageable PAGA claims would effectively graft a class action requirement onto PAGA claims, undermining a core principle" that...
