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PAGA Paraphrased — Rodriguez v. Lawrence Equip., Inc.

The Second District again held that issue preclusion barred plaintiff’s PAGA claim because he failed to establish any violation of the Labor Code and arbitral findings have a preclusive effect on a plaintiff’s standing in a...more

PAGA Paraphrased – Stone v. Alameda Health System

Seyfarth Synopsis: The California Supreme Court held that PAGA does not apply to public entity employers....more

PAGA Reform: AB 2288 and SB 92 Passed

PAGA reform was officially introduced in the state Assembly and Senate! The language of the bills were released detailing the most substantive changes to PAGA in its 20-year history, and Governor Newsom signed them into law...more

PAGA Paraphrased – AB 2288 and SB 92

AB 2288 and SB 92 collectively amount to the most substantive changes ever to be seen to PAGA. The changes include numerous pro-employer provisions which seek to address longstanding concerns such as standing, penalties, and...more

PAGA Reform: AB 2288 and SB 92 Introduced

Seyfarth Synopsis: PAGA reform has officially been introduced in the state Assembly and Senate! The language of the bills were released detailing the most substantive changes to PAGA in its 20-year history. The bills have...more

Governor Newsom Announces PAGA Reform

Governor Newsom announced that a deal has been made to reform PAGA and take the PAGA initiative off the ballot in November. The Governor’s announcement provides some highlights of what the reform package will include;...more

PAGA Paraphrased – Balderas v. Fresh Start Harvesting, Inc.

The Second District, following Adolph and not Viking River, confirms that a PAGA plaintiff does not lose standing to pursue a PAGA claim if they “did not file an individual cause of action seeking individual relief.”...more

Avoid Drama With A Regular Rate Check-Up for Healthcare Employers

California healthcare employers are facing primetime levels of costly litigation alleging claims based on miscalculation of the regular rate of pay. Healthcare employers are often targets because non-exempt healthcare...more

The California Supreme Court Pulls The Carpet Out From Underneath Employers

Seyfarth Synopsis: On January 18, 2024, in Estrada v. Royalty Carpet Mills, Inc., the California Supreme Court addressed the split in appellate authority as to whether trial courts have inherent authority to strike a PAGA...more

PAGA Paraphrased – Estrada v. Royalty Carpet Mills, Inc.

Seyfarth Synopsis: The California Supreme Court addressed the split in appellate authority and held that trial courts do not have the inherent authority to strike a PAGA claim on manageability grounds....more

PAGA Paraphrased – DeMarinis v. Heritage Bank of Commerce

Seyfarth Synopsis: The first reported PAGA case of 2024 serves as a reminder of the importance of precise language for an enforceable PAGA waiver and the risks of including a “poison pill” provision in a...more

PAGA Paraphrased – Nickson v. Shemran, Inc., 90 Cal.App.5th 121 (2023)

Seyfarth Synopsis: The Fourth District joined the Second District in issuing another published decision holding that plaintiffs do not lose representative standing once their individual PAGA claims are compelled to...more

PAGA Paraphrased – Seifu v. Lyft, Inc., 89 Cal.App.5th 1129 (2023)

Seyfarth Synopsis: Another panel from the Second Appellate District issued an opinion, following Galarsa, Piplack, and Gregg, holding that a PAGA plaintiff compelled to individual arbitration retains standing to bring a...more

PAGA Paraphrased – Gregg v. Uber Technologies, Inc., 89 Cal.App.5th 786 (2023)

Seyfarth Synopsis: The Second Appellate District entered the fray and, like the Fourth and Fifth Districts in Galarsa and Piplack, held that an individual PAGA representative still maintains standing to pursue non-individual...more

PAGA Paraphrased – Piplack v. In-N-Out Burgers, 88 Cal.App.5th 1281 (2023)

Seyfarth Synopsis: The Fourth Appellate District provides further support that plaintiffs do not lose representative standing once their individual PAGA claims are compelled to arbitration. In doing so, it rejected the...more

PAGA Paraphrased – Galarsa v. Dolgen California, LLC, 88 Cal.App.5th 639 (2023)

Seyfarth’s Wage Hour Litigation practice group is excited to share this inaugural post in our new series, PAGA Paraphrased. The everchanging world of PAGA is full of verbose opinions, unwieldy statutory language, and a unique...more

California’s (Modern) Family Leave

Seyfarth Synopsis: In 2020, California enacted SB 1383 which, as of January 1, 2021, amended Government Code section 12945.2 to expand the California Family Rights Act (“CFRA”). These changes will require employers who have...more

Fall Into Handbook And Policy Update Season

Seyfarth Synopsis: Although there’s no right or wrong time to do a handbook and policy update, we recommend doing them annually, as California law continually changes. Fall is a good touch point to make changes for the next...more

Is a Purchase in Bankruptcy Really Free and Clear of Liability During COVID-19?

Seyfarth Synopsis: In acquiring a company in bankruptcy, there is often a tendency to think this guarantees the purchaser will be “free and clear” of any liability (including so-called “successor liability”). This is not...more

Is Your Employee As Fit As A Fiddle?

Seyfarth Synopsis: While employees often will toot their own horn, employers sometimes may have concerns about their ability to safely perform their job. If this situation rings a bell, it will be music to your ears to hear...more

A Unique Approach to Class-wide Settlement?

Seyfarth Synopsis: On January 18, 2019, in Porath v. Logitech, Case No. 18-CV-3091 (N.D. Cal. Jan. 18, 2019), Judge William Alsup of the U.S. District Court for the Northern District of California rejected, for the second...more

When The End Is Near for Departing Employees, Don’t Do It Your Way

Seyfarth Synopsis: While Mr. Sinatra could get away with doing things his way, California law requires that employers provide employees facing the final curtain with specific paperwork and a check on their final day. ...more

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