California Supreme Court Watch

Jun 22, 2022
Estrada v. Royalty Carpet Mills, Inc., S274340.

#22-170 Estrada v. Royalty Carpet Mills, Inc., S274340. (G058397, G058969; 76 Cal.App.5th 685; Orange County Superior Court; 30-2013-00692890.) Petition for review after the Court of Appeal affirmed in part and reversed in part the judgment in a civil action. The court limited review to the following issue: Do trial courts have inherent authority to ensure that claims under the Private Attorneys General Act (Lab. Code, § 2698 et seq.) will be manageable at trial, and to strike or narrow such claims if they cannot be managed?

Petition for review granted; issues limited: 06/22/2022

Case fully briefed: 9/26/2022

Cause argued and submitted: 11/08/2023

Opinion filed; judgment affirmed in full: 1/18/2024

See the Court of Appeal Opinion.

See the Petition for Review.

See the Oral Argument.

In the news:  May Courts Strike Unmanageable PAGA Claims? California Supreme Court to Answer, National Law Review (July 20, 2022).

See the California Supreme Court Opinion.  (Estrada v. Royalty Carpet Mills, Inc. (2024) 15 Cal.5th 582.)

“The Courts of Appeal have reached contrary conclusions as to whether trial courts have the inherent authority to strike a Labor Code Private Attorneys General Act of 2004 (PAGA; Lab. Code, § 2698 et seq.) claim on manageability grounds….  We granted review to consider the issue.

We now conclude that trial courts lack inherent authority to strike PAGA claims on manageability grounds.  In reaching this conclusion, we emphasize that trial courts do not generally possess a broad inherent authority to dismiss claims.  Nor is it appropriate for trial courts to strike PAGA claims by employing class action manageability requirements.  And, while trial courts may use a vast variety of tools to efficiently manage PAGA claims, given the structure and purpose of PAGA, striking such claims due to manageability concerns — even if those claims are complex or time-intensive — is not among the tools trial courts possess.

Accordingly, we affirm the Court of Appeal’s judgment as that court reached the same conclusion we reach here.”  [Fns. omitted.]

Chief Justice Guerrero authored the opinion of the Court, in which Justices Corrigan, Liu, Kruger, Groban, Jenkins, and Evans concurred.