Estrada v. Royalty Carpet Mills (2024) 15 Cal.5th 582 did not create the manageability doctrine, but it established the constitutional floor: due process requires that representative proceedings allow the defendant to present individualized defenses. When a PAGA claim spans multiple job classifications, multiple locations, or multiple compensation structures, representative treatment of all claims in a single proceeding may violate this principle.\n\nThe 2024 reforms codified this in § 2699(p): 'The court may limit the evidence to be presented at trial or otherwise limit the scope of any claim filed pursuant to this part to ensure that the claim can be effectively tried.' This is not a suggestion. It is an invitation for defense counsel to file manageability motions limiting the PAGA claim to the violations, employees, and time periods that can be representatively adjudicated — and excluding the rest.\n\nThe practical application: a staffing firm with employees at 14 different client worksites, each with different scheduling practices and break policies, has a strong manageability argument. A hotel chain with properties in different cities under different local ordinances has a strong manageability argument. A dealership group with commissioned salespeople, flat-rate technicians, and salaried managers in the same PAGA notice has a strong manageability argument. Each of these scenarios creates individualized proof requirements that representative treatment cannot adequately address.\n\nThe motion should be filed early — ideally in connection with the early evaluation conference request under § 2699.3(f). Waiting until trial to raise manageability forfeits the opportunity to narrow the case before the bulk of discovery costs are incurred.