California employment case index

Does every PAGA action contain an individual claim an employer can compel to arbitration? The split the California Supreme Court will resolve.

In Naranjo II (2024) 15 Cal.5th 1056, the California Supreme Court holds that an employer’s objectively reasonable, good-faith belief that its wage statements complied with the law defeats both Labor Code § 226 penalties (no “knowing and intentional” violation) and § 203 waiting-time penalties (no “willful” failure) — harmonizing the two penalty statutes around a common good-faith defense.

Estrada v. Royalty Carpet Mills, Inc. (2024) 15 Cal.5th 582 holds that trial courts lack inherent authority to strike a PAGA claim as unmanageable, even if it is complex or time-intensive. Manageability is a class-action requirement that does not apply to PAGA; complexity must be handled through ordinary case-management tools, not dismissal.

Adolph v. Uber Technologies, Inc. (2023) 14 Cal.5th 1104 holds that a PAGA plaintiff whose individual claims are compelled to arbitration retains standing as an “aggrieved employee” to litigate the non-individual representative claims in court — California’s answer to the standing question left open by Viking River.

The FAA preempts Iskanian to the extent it bars division of a PAGA action and prevents arbitration of an employee’s individual PAGA claim; an employer may compel the individual PAGA claim to arbitration. (The Supreme Court further opined that, under its reading of California law, the plaintiff would then lack standing…

Naranjo v. Spectrum Security Services, Inc. (Naranjo I)Premium pay owed for missed meal and rest breaks under Labor Code section 226.7 constitutes “wages,” so it must be reported on wage statements under section 226 and is subject to waiting-time penalties under section 203 when not timely paid at separation.Naranjo v. Spectrum Security Services, Inc. (2022) […]

Settling and dismissing individual Labor Code claims does not strip an employee of standing to pursue a PAGA claim. PAGA standing depends on being an “aggrieved employee” — someone employed by the alleged violator against whom one or more Labor Code violations were committed — not on maintaining an unredressed…