California High Court's PAGA Decision Curtails Manageability Defense
Highlights
The California Supreme Court ruled Private Attorneys General Act (PAGA) claims cannot be dismissed due to “manageability” concerns
Trial courts can use existing case management tools for efficient PAGA trials
Employers should ensure labor code compliance to mitigate risks of complex PAGA litigation
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.
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