Due to the involvement of hundreds of parties and numerous complex legal issues, California trial courts have the discretion to dismiss lawsuits in their entirety if they are deemed "unmanageable." This discretion to dismiss lawsuits for lack of manageability is highly advantageous to employers as it spares them the significant costs and burdens associated with litigating large and intricate cases.
However, there has been a growing split among appellate courts over whether trial courts can dismiss or strike Private Attorneys General Act (PAGA) claims entirely for lack of manageability, a split that ultimately awaits resolution by the California Supreme Court. Adding to this split is recent Court of Appeal decision Nicole Woodsworth v. Loma Linda University Medical Center (2023) which has sided with previous employee-friendly precedent holding that courts cannot strike PAGA claims entirely on the basis of manageability.
In Woodworth, the plaintiff, a former registered nurse at Loma Linda University Medical Center, initially filed a class action alleging wage and hour violations and later added a PAGA claim. The medical center tried to strike all PAGA allegations, arguing unmanageability. The trial court denied the motion in favor of Woodworth, but the medical center's arguments were still considered as potential grounds to dismiss the PAGA claim.
On appeal, the Court referenced two Court of Appeal decisions made after the initial Woodsworth trial: Wesson v. Staples the Office Superstore, LLC (2021) and Estrada v. Royalty Carpet Mills, Inc. (2022).Wesson held that “courts have inherent authority to ensure that PAGA claims can be fairly and efficiently tried and, if necessary, may strike claims that cannot be rendered manageable.” Estrada came to the opposite conclusion. It held that courts “cannot strike a PAGA claim based on manageability,” but they “may still, where appropriate and within reason, limit the amount of evidence PAGA plaintiffs may introduce at trial.” Woodsworth sided with Estrada and held that striking or dismissing PAGA claims based on manageability concerns, as suggested by the medical center, would undermine the purpose of PAGA, which is to supplement enforcement actions by the Labor and Workforce Development Agency (LWDA).
As the issue is set for final review by the California Supreme Court, the Woodsworth decision is by no means the last word on the issue of PAGA manageability concerns. We promise to update readers as soon as our Supreme Court makes its final ruling. Until then, employers would be wise to seek competent employment counsel to ensure compliance with California's complex PAGA regulations.