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California Passes SB 1162, Expanding Pay Data Reporting and Pay Transparency

On September 27, 2022, Governor Newsom signed Senate Bill 1162 (SB 1162), which amends California Government Code section 12999 and California Labor Code section 432.3. SB 1162 expands pay data reporting and increases pay...more

Court of Appeal Holds That Exhaustion of Administrative Remedies Is Procedural, Not Jurisdictional

On September 12, 2022, the California Court of Appeal, 4th District, issued its decision in Acevedo v. CashCall, Inc., 2022 WL 4129106 (Cal. Ct. App. Sept. 12, 2022), affirming the lower court’s decision dismissing a Private...more

CBA Exception Applies to Agreements Retroactively Waiving PAGA Claims

The Private Attorneys General Act (PAGA) contains two industry-specific provisions (Cal. Lab. Code §§ 2699.6 & 2699.8) allowing labor organizations in the construction and janitorial industries to waive the right to bring...more

California Trial Courts Continue To Interpret Johnson v. Maxim Healthcare Narrowly When Applying PAGA’s One-Year Statute of...

Last year, the California Court of Appeal raised eyebrows by ruling that a plaintiff could pursue a Private Attorneys General Act (PAGA) claim for alleged violations of Labor Code Section 432.5, even though the statute of...more

Court of Appeal Case Explains Why Failure to Exhaust Administrative Remedies May Prevent Substitution of PAGA Plaintiffs

On June 9, 2022, the California Court of Appeal, 4th District, issued its decision in Hargrove v. Legacy Healthcare, Inc., No. E076240, 2022 WL 2071982 (Cal. Ct. App. June 9, 2022), which affirmed a trial court decision...more

California Supreme Court Rules That Unpaid Break Premiums May Give Rise to Derivative Penalties

Key Points - On May 23, 2022, in Naranjo v. Spectrum Security Services, Inc., the California Supreme Court held that a failure to provide premium pay for meal or rest break violations under California Labor Code § 226.7...more

Split of Authority Develops in California Court of Appeal Over PAGA Manageability Requirement

On March 23, 2022, in Estrada v. Royalty Carpet Mills, Inc., the California Court of Appeal, held that “a court cannot strike a PAGA claim based on manageability.” This decision creates a split of authority with Wesson v....more

PAGA’s Greatest Hits: Arias v. Superior Court

With the U.S. Supreme Court set to hear oral argument later this month in Viking River Cruises, Inc. v. Moriana, Case No. 20-1573, much of the wage and hour bar has turned its attention to Iskanian v. CLS Transportation Los...more

"Surprised” Court of Appeal Rules That PAGA Plaintiffs Have No Right to a Jury

On February 18, 2022, in LaFace v. Ralphs Grocery Co., 2022 WL 498847 (Cal. Ct. App. Feb. 18, 2022), the California Court of Appeal (2nd District) ruled in a published decision that there is no right to a jury trial in claims...more

How an Insufficient LWDA Notice Led to a Dismissal with Prejudice for One PAGA Plaintiff

On January 14, 2022, in Lehauli v. All Nippon Airways Co., Case No. 21STCV02847, Judge Holly J. Fujie of the Los Angeles Superior Court granted the defendant’s motion for judgment on the pleadings, finding that the plaintiff...more

Recent PAGA Settlement Demonstrates Why PAGA Cases Are Typically Worth Far Less Than the Maximum Theoretical Recovery

On January 11, 2022, Judge Cunningham of the Los Angeles Superior Court conditionally approved a $7.5 million agreement to settle three overlapping Private Attorneys General Act (PAGA) actions, the lead case titled Reyes v....more

LWDA Weighs In on Split of Authority Regarding Standing to Intervene to Challenge PAGA Settlement

In recent months, a split of authority has emerged in the California Court of Appeal regarding whether a nonparty aggrieved employee has standing to intervene in a Private Attorneys General Act (PAGA) action to challenge a...more

A Post-Epic Systems Challenge to Iskanian Has Been Taken Up by the U.S. Supreme Court

In Iskanian v. CLS Transportation Los Angeles, LLC, 59 Cal. 4th 348 (2014), the California Supreme Court held that an arbitration agreement purporting to waive the right to bring a representative action under the Private...more

Court of Appeal Holds That Only Default PAGA Penalties Are Available for Inaccurate Wage Statements

On December 1, 2021, the California Court of Appeal (4th District) issued its decision in Gunther v. Alaska Airlines, Inc., Case No. D076762, holding that heightened penalties for wage statement violations under Labor Code...more

Court of Appeal Defines Standard of Review for PAGA Settlements

On November 30, 2021, the California Court of Appeal (First District) issued its decision in Moniz v. Adecco USA, Inc., Case No. A159410, 2021 WL 5578298, which defines the standard for courts to apply when reviewing...more

Court of Appeals Clarifies What Types of Allegations May Be Cured Under Section 2699.3

On October 7, 2021, the California Court of Appeal (4th District) issued its decision in Quinonez v. Payless 4 Plumbing, Inc., Case No. E074467, clarifying what allegations in a notice letter to the Labor and Workforce...more

Court of Appeal Holds That Exhaustion Requires Identification of Each Separate Theory of Liability (Update)

On September 30, 2021, the California Court of Appeal (4th District) decided Uribe v. Crown Building Maintenance Co., Case No. G057836. At issue in Uribe was a Private Attorneys General Act (PAGA) settlement that purported to...more

PAGA Repeal May Be On the Ballot in 2022

Earlier this month, a coalition including the California Chamber of Commerce, California New Car Dealers Association and Western Growers filed a proposed initiative measure entitled The Fair Pay and Employer Accountability...more

PAGA Settlement May Release Claims from Outside of the Limitations Period

On September 28, 2021, the California Court of Appeal (4th District) issued a counterintuitive decision in Amaro v. Anaheim Arena Mgmt., LLC, Case No. G058371, holding that a PAGA settlement may release claims from outside of...more

Court of Appeal Holds That Exhaustion Requires Identification of Each Separate Theory of Liability

On September 30, 2021, the California Court of Appeal (4th District) decided Uribe v. Crown Building Maintenance Co., Case No. G057836. At issue in Uribe was a Private Attorneys General Act (PAGA) settlement that purported to...more

Not So Fast: Trial Courts Finding PAGA’s Statute of Limitations Is Still Alive and Well After Johnson v. Maxim Healthcare

Earlier this year, the California Court of Appeal ruled that a plaintiff was permitted to pursue a PAGA claim for alleged violations of Labor Code Section 432.5, even though the statute of limitations on her individual claim...more

California Court of Appeal Approves Limiting or Striking Unmanageable PAGA Claims

In Wesson v. Staples The Office Superstore, LLC, the California Court of Appeal held that “courts have inherent authority to ensure that PAGA claims can be fairly and efficiently tried and, if necessary, may strike claims...more

California Supreme Court Holds Break Premiums Must Account For Nondiscretionary Payments In Addition to the Hourly Rate of Pay

Key Points - In Ferra v. Loews Hollywood Hotel, LLC, the California Supreme Court held that premiums paid for missed meal, rest or recovery periods must include nondiscretionary pay, not just hourly wages. The decision...more

Reminder: New California Employment Laws for 2021

Key Points: - Numerous new California laws going into effect on January 1, 2021 (or earlier), will impact employers and employees. - The most significant laws include new obligations to report employee pay data, an...more

California Supreme Court Holds That Unpaid Wages Are Not Recoverable Under PAGA

• On September 12, 2019, in ZB, N.A. v. Superior Court (Lawson), Case No. S246711, the California Supreme Court held the Private Attorneys General Act (PAGA) does not allow recovery of unpaid wages under Labor Code Section...more

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