California High Court's PAGA Decision Curtails Manageability Defense

The California Supreme Court’s recent decision in Estrada v. Royalty Carpet Mills, Inc. removes manageability as a viable basis for dismissal of California Private Attorneys General Act (PAGA) claims, distinguishing those claims from class actions where such a factor may be crucial for certification. This ruling not only underscores the procedural and legislative distinctions between class actions and representative PAGA actions, but also signals a broader implication for employers in managing and defending against California Labor Code violations within the context of PAGA.