LYFT
On August 1, 2024, in Turrieta v. Lyft, Inc., the California Supreme Court clarified an important procedural issue that relates to the resolution of Private Attorney General Act (PAGA) matters. Most PAGA lawsuits, which are brought in the name of the government (but are not coordinated or controlled by the government) wage and hour group action, are resolved at mediation. Just how much certainty those settlements provided, however, has been in flux in the wake of some evolving caselaw form the Courts of Appeal about whether another PAGA plaintiff with overlapping claims could nonetheless intervene in or object to the settlement and block the complete resolution of all PAGA claims by all Plaintiffs.
Relying heavily on the express language of PAGA and its legislative history, the Court concluded:
"We find no evidence in the legislative history that the Legislature either intended to confer on PAGA plaintiffs the intervention power... or understood that PAGA confers such power."
"The Legislature's failure to address any of these topics or include any such provisions in PAGA is a factor that supports the conclusion that the scope of... statutory authority under PAGA does not include the power to intervene."
The Court reinforced its statutory construction with arguments from public policy – i.e., explaining what California employers and wage and hour attorneys know to be true, that failing to limit intervention would open the door to legion inefficiencies, as practicably every PAGA settlement would be open to attack by would-be-intervenors, creating disputes over claim authority, fee awards, and generally eroding most (if not all) confidence an employer could achieve by resolving PAGA claims. The Court also noted that in other qui tam, or representative suits, when the State had provided the power to intervene, it had done so explicitly, leading to the conclusion that the absence of such language in the PAGA statute meant the legislature did not intend to give one Plaintiff the right to interfere with another Plaintiff's settlement.
In other words, the blood and treasure that California employers place into defending and resolving PAGA claims have become significantly more valuable in the wake of the Turrieta ruling. This ruling, in conjunction with the recent PAGA amendments, means that California employers no longer need to worry about having to "double-pay" for duplicative PAGA lawsuits, if they achieve a reasonable and court-approved settlement at mediation that covers all competing claims. As such, plaintiffs (and counsel) with competing claims may be more inclined (or forced) to cooperate with existing counsel, lest those who are not at the table when a deal is struck be left empty-handed.
For employers navigating the challenges of labor litigation in California, understanding these procedural nuances is critical.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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