Alerts2.15.24

California High Court's PAGA Decision Curtails Manageability Defense

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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