News & Analysis as of

Employment Litigation Private Attorneys General Act (PAGA) Employees

Seyfarth Shaw LLP

PAGA Paraphrased – Osuna v. Spectrum Security Services, Inc.

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The Second District Court of Appeal held that, under the pre-reform PAGA statute, an individual employee need not have been employed or experienced a Labor Code violation during the one-year PAGA limitations period to have...more

Seyfarth Shaw LLP

PAGA Paraphrased – Rose v. Hobby Lobby Stores, Inc.

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The First District held that a prevailing defendant in a PAGA action may not recover litigation costs from the California Labor Workforce Development Agency when the LWDA did not participate in the litigation....more

ArentFox Schiff

A PAGA Plaintiff Must Allege a Timely Individual Claim

ArentFox Schiff on

A California Court of Appeal recently held that an employee bringing a claim under the Private Attorneys General Act (PAGA) must be able to allege that he personally suffered a Labor Code violation within the applicable...more

Snell & Wilmer

PAGA Reform Benefits Proactive Employers

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In 2024, California reformed its Private Attorneys General Act (“PAGA”) for the first time in the statute’s two-decade history. The reforms were less drastic than some had hoped, but they afford employers new avenues for...more

Seyfarth Shaw LLP

PAGA Paraphrased – Parra Rodriguez v. Packers Sanitation, Inc.

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The Fourth District held that a motion to compel arbitration is not the correct vehicle to challenge a plaintiff’s failure to plead the individual component of a PAGA claim affirming the Superior Court’s denial of a motion to...more

Ervin Cohen & Jessup LLP

Every PAGA Action Has An Individual Component Which May Be Subject To Arbitration

Prior to the United States Supreme Court’s decision in Viking River Cruises Inc. v. Moriana, California courts did not consider the components of a Private Attorneys General Act (“PAGA”) claim. ...more

K&L Gates LLP

California Court of Appeal Ends Headless PAGA Actions in Leeper v. Shipt

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The California Court of Appeal, Second Appellate District, in Leeper v. Shipt, Inc., No. B339670, 2024 WL 5251619 (Cal. Ct. App. Dec. 30, 2024) (Leeper) issued a significant decision benefiting employers seeking to enforce...more

Fox Rothschild LLP

Doing Business in California Guide Updated for 2025

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The allure of doing business in California is undeniable. It is the world’s fifth (and moving towards fourth) largest economy and a market of over 39 million people. For employers, however, California presents unique...more

Ballard Spahr LLP

California Court of Appeal Says No More “Headless” PAGA Lawsuits

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In an effort to avoid arbitrating individual claims under the Private Attorneys General Act (“PAGA”), a recent trend emerged in California litigation involving “headless” PAGA lawsuits. Essentially, plaintiffs would expressly...more

Polsinelli

California Court of Appeal Invalidates Headless PAGA Actions

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In a decision with significant impact for employers defending Private Attorney General Act (PAGA) cases, a California 2nd District Court of Appeal panel ruled on December 30, 2024, that plaintiffs cannot circumvent...more

Vorys, Sater, Seymour and Pease LLP

California Court of Appeal Leaves ‘Headless’ PAGA Claims Lifeless

In a significant development for California employers, the California Court of Appeal’s decision in Leeper v. Shipt, Inc. closed out 2024 by strengthening the enforceability of arbitration agreements in Private Attorneys...more

Epstein Becker & Green

California Court of Appeal Holds That Every PAGA Action Necessarily Includes an Individual PAGA Claim – and Plaintiffs With...

Following the United States Supreme Court’s decision in Viking River Cruises, Inc. v. Moriana (2022) U.S. 639 and the California Supreme Court’s decision in Adolph v. Uber Technologies, Inc. (2023) 14 Cal. 5th 1104, when...more

CDF Labor Law LLP

Last Ride For “Headless” PAGA Actions

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Yesterday, the California Court of Appeal in Leeper v. Shipt, Inc., held that because every PAGA action necessarily includes an “individual PAGA claim” a PAGA plaintiff cannot avoid arbitration by asserting purely...more

Seyfarth Shaw LLP

PAGA Paraphrased — Rodriguez v. Lawrence Equip., Inc.

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The Second District again held that issue preclusion barred plaintiff’s PAGA claim because he failed to establish any violation of the Labor Code and arbitral findings have a preclusive effect on a plaintiff’s standing in a...more

CDF Labor Law LLP

LWDA Publishes PAGA Frequently Asked Questions

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The California Labor & Workforce Development Agency (“LWDA”) recently published Frequently Asked Questions pertaining to the Private Attorneys General Act (“PAGA”) and the recent amendments that impact PAGA claims after June...more

CDF Labor Law LLP

2024 PAGA Reforms – Has the Landscape Changed?

CDF Labor Law LLP on

The Private Attorneys General Act (PAGA), enacted in 2004, upturned California’s employment law landscape. In theory, PAGA allowed employees to file lawsuits to recover civil penalties on behalf of themselves, other...more

Lewitt Hackman

PAGA: Early Evaluation Conference

Lewitt Hackman on

This is the final of a three-part series addressing the changes to California’s Private Attorneys General Act. In this part we discuss the Early Evaluation Conference....more

Epstein Becker & Green

Do the PAGA Amendments Create a Trap for California Employers? Yes. Are They Likely to Reduce the Number of PAGA Actions? No.

Epstein Becker & Green on

Much has been made about the recent, hurried legislation to amend the Private Attorneys General Act (“PAGA”) in order to take the Fair Pay and Employer Accountability Act (“FPEAA”) off the California ballot this November....more

Downey Brand LLP

Key Changes to PAGA and What Employers Should Know

Downey Brand LLP on

Last week, Governor Newsom signed Assembly Bill (AB) 2288 and Senate Bill (SB) 92, which amended California’s Private Attorneys General Act (PAGA).  Since 2004, PAGA has created challenges for California employers because it...more

Akerman LLP - HR Defense

Is the Wicked Witch Really Dead? California Passes Long Anticipated PAGA Reforms, But Do They Really Help Employers?

In a lightning-fast deal brokered by Governor Gavin Newsom, California lawmakers enacted significant amendments to PAGA, California’s so-called “sue-your-boss” law that deputizes millions of workers across the state to bring...more

K&L Gates LLP

UPDATE: California Legislature Amends PAGA Statute Through Assembly Bill 2288 and Senate Bill 92

K&L Gates LLP on

Assembly Bill 2288 and Senate Bill 92 were introduced on 21 June 2024, both of which proposed significant reforms to California’s Private Attorneys General Act of 2004 (PAGA). On 1 July 2024, Governor Gavin Newsom signed...more

Polsinelli

PAGA Amendments Aim to Bring PAGA Litigation Under Control

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California’s Private Attorneys General Act (“PAGA”) has undergone substantial, and arguably overdue, reform by way of dual legislative measures - Assembly Bill 2288 and Senate Bill 92. PAGA 2.0 will apply to PAGA civil...more

Perkins Coie

California Significantly Amends Private Attorneys’ General Act

Perkins Coie on

Over the years, California’s Private Attorneys General Act of 2004 (PAGA) has provided a procedurally convenient means for employees to seek expansive penalties for employers’ alleged violations of California’s very technical...more

Saul Ewing LLP

What You Need To Know About California's PAGA Reform

Saul Ewing LLP on

On July 1, 2024, Governor Newsom signed legislation that makes significant changes to California's notorious Private Attorneys General Act (PAGA) to become effective immediately as an urgency measure. While the new...more

Mintz - Employment Viewpoints

A New Chapter in California’s Ongoing PAGA is Lava Saga: PAGA Reform

Aggrieved employee is any person who was employed by the alleged violator and against whom one or more of the alleged violations was committed. An “aggrieved employee” is any person who was employed by the alleged violator...more

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