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PAGA & Manageability

In a court decision that Employment Lawyers have been waiting for the California Supreme Court held that trial courts may not strike Private Attorney General Act (“PAGA”) claims on manageability grounds. 

Just yesterday, the California Supreme Court in Estrada v. Royalty Carpet Mills, Inc. addressed the circuit split regarding the Court’s authority to strike down PAGA claims on the ground that they were not manageable. Manageability, which has been applicable to Class Action lawsuits, has been a longstanding defense for employers in PAGA claims which we wrote about previously in our article Are PAGA Claims Manageable.

The California Supreme Court in Estrada has disappointedly rejected the argument that class manageability requirements could be applied to PAGA claims where they otherwise do not exist. The Court emphasized the clear distinction between class action and PAGA cases and how their procedures differ in their rationale for their decision.  While the Court ruled that trial courts do not have the inherent authority to strike a PAGA claim, the Court did make clear, that trial courts still have the authority to limit the scope of evidence presented at a PAGA trial based on manageability grounds.

While the Court’s holding is a blow to employers, there is still room to for Employer attorneys to address manageability in PAGA lawsuits at trial. The California Supreme Court’s decision reinforces, and further highlights the importance of making sure you are running your business California Labor Law Compliant to minimize your risk of PAGA and/or Class Action lawsuits. Are you sure you are running your business labor law compliant? To learn more about CA labor law compliance or what this decision means for your PAGA case contact the Employer Lawyers at Chauvel & Glatt.

This material in this article, provided by Chauvel & Glatt, is designed to provide informative and current information as of the date of the post. It should not be considered, nor is it intended to constitute legal advice.  For information on your particular circumstances, please contact  Chauvel & Glatt at 650-573-9500 for legal assistance near you. (photo credit: depositphotos.com).

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