California PAGA Cases All Have Individual Claims, Justices Say

Every action to enforce the state labor code under California’s Private Attorneys General Act inherently includes an individual claim, a state appeals panel ruled on Monday.

Despite a worker saying her lawsuit against a Target subsidiary contained only claims on behalf of an employee group, justices directed part of her case into arbitration.

The published opinion pointed to the limits of a recent ruling that worker-side attorneys have cited to bring “headless” claims in California court, to avoid the delays and possible issue preclusion that come with arbitration.

“Based on the unambiguous, ordinary meaning of the relevant statutory language and ...