Leeper v. Shipt, Inc. (S289305) has been fully briefed since the amicus wave closed in January. Parra Rodriguez v. Packers Sanitation Services (S290182) and CRST Expedited (S292005) sit behind it as grant-and-holds, and the conference minutes have kept adding companions. The court's published 2026 calendar seats no July or August session — the remaining sittings run September through December — and the ninety-day decision clock starts only at argument. The earliest realistic window for an answer to the headless-PAGA question is fall 2026, and winter is likelier.
The split the court will resolve has hardened into a clean map. Leeper v. Shipt (2024) 107 Cal.App.5th 1001 and Williams v. Alacrity Solutions Group (2025) 110 Cal.App.5th 932 read section 2699(a)'s 'and' as conjunctive: every PAGA action includes an individual claim, so there is always something to compel to arbitration. Balderas v. Fresh Start Harvesting (2024) 101 Cal.App.5th 533 and CRST Expedited (2025) 112 Cal.App.5th 872 — the decision that squarely permitted a headless action under the pre-reform statute — read the same word the other way. Parra Rodriguez decided less than it is cited for: it affirmed the denial of a motion to compel because the complaint as drafted pleaded no individual claim, locked the plaintiff into that disclaimer through judicial estoppel, and expressly reserved whether such a complaint is properly pleaded at all.
The holding pattern is not a reason to wait. It is a reason to preserve. In every pending case with an arbitration agreement, the defense should be running both tracks simultaneously: the motion to compel individual claims under Viking River and Adolph, and the standing challenge under section 2699(c)(1) — which, for post-reform notices, requires that the plaintiff personally suffered each violation alleged. A defendant who briefs only the track that matches its prediction of Leeper will spend 2027 explaining the forfeiture.
Two quieter moves belong in the same file. First, plead the judicial-estoppel position Parra Rodriguez validated: if the complaint disclaims individual relief to defeat arbitration, the disclaimer should follow the plaintiff for the life of the case. Second, watch the grant-and-hold list — every addition is a case whose posture the court considered close enough to hold, and the list is a map of the fact patterns the decision will have to govern.
The bottom line: nothing about Leeper rewards prediction, and everything about it rewards preservation. The decision will arrive no earlier than fall. The record you build between now and then decides what you can do with it.