Estrada v. Royalty Carpet Mills, Inc.

(2024) 15 Cal.5th 582

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, multi-classification employers win.

Holding

Trial courts do not have inherent authority to strike or dismiss PAGA claims on manageability grounds. But courts retain extensive tools: representative testimony, surveys, statistical analysis, limiting evidence, and scope limitation. Codified by AB 2288 in Lab. Code § 2699(p).

Impact on Defense Practice

The most powerful defense tool in the post-reform landscape — not as a dismissal mechanism, but as a scope-limitation tool. Claims requiring individualized proof across multiple job classifications can be narrowed before trial.

Defense Strategy

Build the manageability argument from day one. Document job classification differences, location-specific practices, and individual variation. Demand detailed trial plans from plaintiffs early. Use AB 2288's § 2699(p) to seek pre-trial orders limiting claims and evidence — the statutory text arguably authorizes pre-trial scope limitation, going further than Estrada alone.

This analysis is for informational purposes only. Case law is current as of Q1 2026.