Akin Gump published a client alert on the California Court of Appeal's March 23, 2022, decision in Estrada v. Royalty Carpet Mills, Inc., Case No. G058397. The court held that "a court cannot strike a Private Attorneys General Act (PAGA) claim based on manageability." Estrada, 2022 WL 855568, at *1. This decision creates a split of authority with Wesson v. Staples The Office Superstore, LLC, 68 Cal. App. 5th 746 (2021), and raises the possibility that the California Supreme Court will need to decide the issue.
Estrada explained that, under its holding, a trial court may still limit the evidence that may be admitted at trial in order to ensure a manageable trial, and that a PAGA plaintiff seeking to try an unmanageable claim "risk[s] being awarded a paltry sum of penalties, if any," due to problems of proof. The Court also encouraged plaintiffs to work with trial courts to "define a workable group or groups of aggrieved employees," including by "narrowing alleged violations to employees at a single location or department." Estrada, 2022 WL 85568, at *12 & n.8.
To read the full alert, please click here.
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