Every PAGA Claim Necessarily Includes An Individual PAGA Claim.
We like it when judges neatly summarize a case and its ruling. It makes it much easier to do a quick post. Justice Frances Rothschild has made our job easier:
Shipt, Inc. (Shipt) and its parent company Target Corporation (Target) (collectively, appellants) appeal from an order denying their motion to compel arbitration in an action brought against them by respondent Christina Leeper under the Private Attorneys General Act of 2004 (Lab. Code, § 2698 et seq.) (PAGA). The court denied the motion on the basis that Leeper’s PAGA action did not allege any individual claims subject to arbitration under the parties’ arbitration agreement.
Based on the unambiguous, ordinary meaning of the relevant statutory language and the legislative history of that language, however, we conclude that every PAGA action necessarily includes an individual PAGA claim.2 Accordingly, we reverse and direct the court to enter a new order (1) compelling the parties to arbitrate Leeper’s individual PAGA claim and (2) staying the representative PAGA claim portion of the lawsuit.
Christina Leeper v. Shipt, Inc., et al, B339670 (2/1 12/30/24) (Rothschild, Weingart, Klatchko).
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