California Supreme Court
Estrada v. Royalty Carpet Mills, Inc.
January 18, 2024
Summary
The court held that trial courts lack inherent authority to dismiss or strike a PAGA claim solely because it is difficult to manage, including by importing class-action manageability requirements. PAGA claims are statutory enforcement actions with purposes and procedures distinct from class actions, although courts may use case-management tools to conduct them fairly and efficiently. The court also rejected the defendant’s claim that retrial would violate due process because the defendant had not shown a right to present unlimited individualized testimony. The opinion was unanimous and contains no separate writings.