Case Law Laboratory
15 decisions. Each one changed how PAGA defense is practiced. From Kirby's foundational distinction between wages and penalties to Hohenshelt's reversal of five years of strict-liability authority. Each analysis runs the full arc — the dispute, the court's reasoning, subsequent developments, and a numbered defense playbook.
Adolph v. Uber Technologies, Inc.
The arbitration playbook changed overnight. Individual claims go to arbitration, but the representative PAGA action stays in court — and the plaintiff keeps standing. Defense…
Estrada v. Royalty Carpet Mills, Inc.
Courts cannot dismiss PAGA on manageability grounds — but they can narrow scope dramatically. AB 2288 codified this in § 2699(p). This is where multi-location…
Donohue v. AMN Services, LLC
Every short meal punch in the time-clock data now creates a rebuttable presumption that the employer failed to provide a compliant meal period. Rounding cannot be used to round…
Hohenshelt v. Superior Court
Five years of strict-liability appellate authority — reversed. Late arbitration fee payment forfeits arbitration only if willful, grossly negligent, or fraudulent. Eleven Court of…
Turrieta v. Lyft, Inc.
A PAGA plaintiff's status as the state's proxy carries no right to intervene in, object to the settlement of, or move to vacate the judgment in another employee's overlapping PAGA…
Stone v. Alameda Health System
Public entities sit outside PAGA entirely — not merely outside its default penalties. A hospital authority, a special district, a joint powers authority: none is a 'person' under…
Iloff v. LaPaille
Ignorance of the minimum wage law no longer defeats the mandatory liquidated damages award. An employer that never asked what the law required cannot fall back on unsettled…
Leeper v. Shipt, Inc.
Can a plaintiff renounce individual PAGA relief entirely and plead a representative-only action that leaves nothing to compel to arbitration? The Supreme Court took the case on…
Ferra v. Loews Hollywood Hotel, LLC
Meal and rest period premiums must be calculated at the regular rate — not base hourly. Applied retroactively. For employees with commissions or bonuses, the gap between base and…
Kirby v. Immoos Fire Protection, Inc.
The § 226.7 premium is a wage, not a penalty. It cannot be recovered as a PAGA penalty. This distinction alone can reduce inflated demands by 30–50%. The foundation of every…
Brinker Restaurant Corp. v. Superior Court
An employer who provides the opportunity for an uninterrupted 30-minute meal period has complied — even if employees voluntarily worked through. But Donohue's rebuttable…
ZB, N.A. v. Superior Court
PAGA recovers civil penalties. Wages are not civil penalties. Overtime underpayments, meal premiums, unreimbursed expenses — none are recoverable through PAGA as penalties. The…
Naranjo v. Spectrum Security Services, Inc.
One missed meal period now generates four separate penalty streams: the premium itself, a PAGA default penalty, a § 226 wage statement penalty, and § 203 waiting time penalties.…
Alvarado v. Dart Container Corp. of California
Flat-sum bonuses must be divided by nonovertime hours only — not total hours. This produces a higher regular rate, increasing both overtime premiums and (after Ferra) meal/rest…
Duran v. U.S. Bank National Assn.
Statistical sampling must satisfy due process. The sample must be representative, the methodology sound, and the defendant must retain the right to challenge individual claims.…