March 29, 2022

Estrada v. Royalty Carpet Mills, Inc. (March 23, 2022, G058397, G058969)

Plaintiff employees brought a Private Attorneys General Act (PAGA) representative claim against their employer for Labor Code violations, including meal period violations. After a bench trial, the trial court dismissed the meal period portion of the PAGA claim on grounds that individualized issues made the claim unmanageable.

The Court of Appeal reversed, holding that courts cannot dismiss a PAGA claim based on whether it is unmanageable, and declining to follow Wesson v. Staples the Office Superstore, LLC (2021) 68 Cal.App.5th 746, which held that courts can strike unmanageable PAGA claims. The court reasoned that dismissing a PAGA claim based on a manageability standard would impose class action procedures on proceedings that are not class actions and would interfere with the enforcement purpose of PAGA. Instead, the court held that courts may limit plaintiffs’ evidence to promote the efficient adjudication of unwieldy PAGA claims.