Ruling in an employee’s case alleging Labor Code violations, the Supreme Court in Estrada v. Royalty Carpet Mills, Inc. yesterday held the authority to dump a class action because it’s unmanageable is not available to superior courts in representative actions under the Labor Code Private Attorneys General Act. Instead, the court endorsed “the unremarkable proposition that trial participants should endeavor in all cases (including PAGA cases) to ensure that a case is efficiently adjudicated.”
The court’s unanimous opinion by Chief Justice Patricia Guerrero says that, “while trial courts may use a vast variety of tools to efficiently manage PAGA claims, given the structure and purpose of PAGA, striking such claims due to manageability concerns — even if those claims are complex or time-intensive — is not among the tools trial courts possess.” The court left open “the hypothetical questions of whether, and under what circumstances, a defendant’s right to due process might ever support striking a PAGA claim,” but it concluded there was no due process violation in the case before it.
Resolving a split of authority, the court affirms the published opinion of the Fourth District, Division Three, Court of Appeal and it disapproves the Second District, Division Four, decision in Wesson v. Staples the Office Superstore, LLC (2021) 68 Cal.App.5th 746. The court had denied review and depublication in Wesson. (See: Disapprovals of review-denied opinions show the Supreme Court is not an error-correction court.)
