On January 18, 2024, the California Supreme Court issued a highly anticipated decision in Estrada v. Royalty Carpet Mills, Inc., determining whether trial courts can dismiss Private Attorneys General Act (PAGA) claims as unmanageable. The Court ultimately concluded that dismissing PAGA claims solely on manageability grounds ' even if those claims are complex or time-intensive ' is not among the tools that trial courts possess but left various other means for limiting or dismissing PAGA claims undisturbed.
PAGA Claims - A Reminder
As many California employers are aware, PAGA allows employees to bring claims on behalf of the state to recover civil penalties for violations of the California Labor Code. In a successful PAGA action, the California Labor and Workforce Development Agency is entitled to 75% of the recovered penalties, and the remaining 25% goes to the "aggrieved employees."
The Split in the California Courts of Appeal
The California Supreme Court's decision resolved a split between the Courts of Appeal in the Second District and the Fourth District over...