On January 18, 2024, the California Supreme Court made a significant ruling in the case of Estrada v. Royalty Carpet Mills, Inc., finding that the trial court lacked the inherent authority to dismiss a California’s Private Attorneys General Act (PAGA) claim based on manageability grounds. Manageability considerations are often used in the class action context, but the Supreme Court has now found it has no applicability in the PAGA context.
PAGA provides for civil penalties for various Labor Code violations and authorizes “aggrieved employees,” acting as private attorneys general, to recover those penalties. A PAGA plaintiff will often seek penalties for violations involving aggrieved employees other than the PAGA plaintiff. Civil penalties recovered on a PAGA claim are split between the state and aggrieved employees, with 75 percent going to state labor law enforcement agency and 25 percent going to aggrieved employees.
“Manageability” in this context refers to a Continue reading