"Bounty Hunters" Lose Their State "Badge" as California Court of Appeal Clarifies Several PAGA Issues

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In a case of first impression regarding the application of California’s Private Attorneys General Act (PAGA) to class action settlements, a California Court of Appeal in Deleon v. Verizon Wireless holds that asettlement agreement of a non-PAGA class action waiving "all claims" bars a subsequent PAGA action on behalf of the same class, even if the state never approved the settlement.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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