"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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