Turrieta v. Lyft, Inc. (2024)
California’s Private Attorneys General Act (PAGA) permits an “aggrieved employee” to bring a representative action on behalf of current or former employees to recover civil penalties for wage-related violations of California’s Labor Code. These are law enforcement actions brought by deputized private attorney general plaintiffs acting as proxies for the State. Trial courts must approve the settlement of such PAGA claims.
Multiple plaintiffs often bring separate PAGA actions asserting overlapping claims. When this occurs, a settlement approved in one of these lawsuits could foreclose or curtail the other overlapping lawsuits. PAGA plaintiffs therefore often try to object to settlements in overlapping PAGA actions, or seek to intervene—or to vacate the judgment—to challenge the proposed settlement. California Courts of Appeal were divided over whether such plaintiffs had the right to do so.
In Turrieta, the California Supreme Court held that one PAGA plaintiff has no right to intervene or move to vacate in an overlapping PAGA action based solely on his or status as the State’s proxy. The Supreme Court also held that trial courts are not required to consider objections to a proposed PAGA settlement from such plaintiffs based on this status.
