Seyfarth Synopsis: The California Supreme Court addressed the split in appellate authority and held that trial courts do not have the inherent authority to strike a PAGA claim on manageability grounds.
In Estrada, the trial court had dismissed the plaintiff's PAGA claim following a bench trial, on the grounds that the claim was "unmanageable." The Supreme Court, agreeing with the Court of Appeal, held that a trial court cannot strike a PAGA claim solely on manageability grounds. In reaching its conclusion, the Supreme Court affirmed that PAGA claims should be manageable and a trial court can, and should, use the full tool box of case management procedures at its disposal to ensure that a PAGA claim is "effectively tried." However, outright dismissal of the PAGA claim due to unmanageability alone is not a tool that the trial court has at its disposal.
The Supreme Court explicitly left open the question as to whether PAGA claims can be stricken to preserve an employer's due process rights and noted that an employer-defendant has a due process right to present affirmative defenses and must be permitted to "introduce its own evidence, both to challenge the plaintiffs' showing and to reduce overall damages" and if plaintiffs seek to use a statistical model to prove their claims, defendants "must be given a chance to impeach that model or otherwise show that its liability is reduced."
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