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Private Attorneys General Act (PAGA) California

Proskauer - California Employment Law

“Headless” PAGA Action May Proceed In Court

CRST Expedited, Inc. v. Superior Court, 2025 WL 1874891 (Cal. Ct. App. 2025) - Espiridion Sanchez filed this PAGA action against his former employer on behalf of himself and other allegedly “aggrieved employees.”...more

CDF Labor Law LLP

CA’s Fifth Appellate District Wades Into “Headless” PAGA Debate

CDF Labor Law LLP on

While we are waiting for the CA Supreme Court in Leeper v. Shipt to address whether “headless” PAGA claims (i.e., where PAGA representative plaintiffs disavow the “individual” portion of a PAGA claim) are a permissible end...more

Seyfarth Shaw LLP

PAGA Paraphrased – CRST Expedited, Inc. v. Super. Ct.

Seyfarth Shaw LLP on

The Fifth District Court of Appeal held that under pre-reform PAGA, headless PAGA actions in which plaintiffs seek civil penalties only on behalf of other employees and not for violations they personally experienced are...more

Sheppard Mullin Richter & Hampton LLP

Will the California Supreme Court Put the Heads Back on Headless PAGA Suits?

Since our last coverage of “headless PAGA lawsuits”—i.e., lawsuits in which a plaintiff disavows his individual PAGA claim and opts to pursue the claim only on behalf of others—significant developments have further...more

Ervin Cohen & Jessup LLP

California Court of Appeal Decision in Rose v. Hobby Lobby: No Recovery of Costs Against Nonparticipating State Agency

On May 14, 2025, the California Court of Appeal issued a decision in Rose v. Hobby Lobby Stores, Inc., addressing whether the California Labor and Workforce Development Agency (LWDA) can be held liable for an employer’s...more

Seyfarth Shaw LLP

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

Seyfarth Shaw LLP on

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

Proskauer - California Employment Law

May 2025 California Employment Law Notes

We invite you to review our newly-posted, May 2025 California Employment Law Notes, a comprehensive review of the latest and most significant developments in California employment law. The highlights include: Apple...more

Seyfarth Shaw LLP

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

Seyfarth Shaw LLP on

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

Reyes v. Hi-Grade Materials Co. – Continuing the Trend to Limit PAGA Gamesmanship

ArentFox Schiff on

The California Fourth District Court of Appeal’s decision in Reyes v. Hi-Grade Materials Co. continues the trend toward limiting plaintiffs’ abuse and improper weaponization of the California Private Attorneys General Act...more

Kelley Drye & Warren LLP

No Individual Claim, No Problem? The California Supreme Court Takes on Circuit Split on Headless PAGA Claims

The Private Attorneys General Act of 2004 (PAGA) grants private individuals the authority to sue on behalf of the state of California for employer violations of the California Labor Code. The primary purpose of PAGA is not to...more

CDF Labor Law LLP

PAGA Tactic Denied by Cal. Court of Appeal: Plaintiff Who Voluntarily Dismissed PAGA Claims Could Not Invoke Death Knell Doctrine...

CDF Labor Law LLP on

Last week, in Chavez v. Hi-Grade Materials Co., the California Court of Appeal took up a novel jurisdictional question: Can a putative class action plaintiff unilaterally ring the death knell for the entire class and create...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

CDF Labor Law LLP

PAGA Update: Cal. Court of Appeal Confirms PAGA Plaintiffs Must Have a Timely Individual PAGA Claim

CDF Labor Law LLP on

In a decision with important implications for many pending Private Attorneys General Act (PAGA) lawsuits, a California Court of Appeal upheld the dismissal of a representative PAGA action as untimely because the plaintiff did...more

Seyfarth Shaw LLP

PAGA Paraphrased – Williams v. Alacrity Solutions Group, Inc.

Seyfarth Shaw LLP on

PAGA claims brought under pre-reform PAGA must be brought within one year of a Labor Code violation experienced by the plaintiff and because a PAGA claim necessarily has both an individual and a non-individual component,...more

Proskauer - California Employment Law

When Headless PAGAs Attack!

As we reported here, a split in authority has developed in the California Court of Appeal regarding what to do when an employer moves to compel arbitration of a Private Attorneys General Act (PAGA) that is “headless”—that is,...more

Jackson Lewis P.C.

Explaining California’s Private Attorneys General Act

Jackson Lewis P.C. on

Employers in California more than likely have heard of the Private Attorneys General Act, commonly referred to as PAGA. However, understanding what it is, how it functions, and how it can affect them can be challenging....more

Troutman Pepper Locke

Labor and Employment Developments in California in 2025

Troutman Pepper Locke on

California often finds itself at the forefront of labor and employment law, with changes affecting employers each year. This year is no different. In 2025, employers can expect a variety of impactful changes to the...more

Proskauer - California Employment Law

For At Least One Employer, Reliance on an Outdated Arbitration Agreement Proved to be a Losing Gamble

As we have reported time and again, California courts have applied extra scrutiny to employee arbitration agreements in recent years, and have not hesitated to deny arbitration where there is a reasonable basis for doing so. ...more

Weintraub Tobin

An Update on PAGA Reform from the Trenches – Finally, Some Relief for Employers from Meritless Claims

Weintraub Tobin on

Last year, we reported on the reforms to the Private Attorney General Act (PAGA) that Governor Gavin Newsom signed into law on July 1, 2024. The reform legislation was pushed through to avoid a ballot vote on a measure...more

Weintraub Tobin

California Employment News: Taking Advantage of the PAGA Reform – How Employers Can Lower Their Risk of PAGA Liability

Weintraub Tobin on

In this episode of California Employment News, Meagan Bainbridge and Ryan Abernethy break down the latest PAGA reforms and what employers need to know to reduce penalties and stay compliant. From new cure opportunities to...more

Proskauer - California Employment Law

The Headless PAGA Saga Continues

On February 26, 2025, in Parra Rodriguez v. Packers Sanitation, Inc., the California Court of Appeal (Fourth Appellate District) issued the latest published decision addressing the practice of filing so-called “headless”...more

Farella Braun + Martel LLP

Navigating Recent Changes to California Wage and Hour Laws

The recent changes to California’s wage and hour laws have significant implications for employers operating within the state. While the reforms are aimed at providing clearer guidelines for employers, there are still complex...more

CDF Labor Law LLP

PAGA Update: Key Lessons for Defending and Settling PAGA Cases

CDF Labor Law LLP on

Two recent Private Attorney General Act (PAGA) cases underscore the importance of effectively using procedural motions in defending such cases. 1.  Rodriguez v. Packers Sanitation Services LTD., LLC...more

Vorys, Sater, Seymour and Pease LLP

California Court Creates Appellate Split On ‘Headless’ PAGA Claims

A recent decision from the California Court of Appeal for the Fourth Appellate District has created a split on whether employees can bring “headless” Private Attorneys General Act (PAGA) claims.  “Headless” PAGA refers to the...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

California Appeals Court Decides PAGA Lawsuit Can’t Be Sent to Arbitration Without Individual Claims

A California court of appeal recently upheld a trial court’s ruling that rejected a sanitation company’s effort to compel arbitration of individual claims under California’s Private Attorneys General Act (PAGA), where the...more

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