California Supreme Court Watch

#25-349 Galarsa v. Dolgen California, LLC, S293545. (F089004, F089171; 115 Cal.App.5th 1; Kern County Superior Court; BCV-19-102504.) Petition for review after the Court of Appeal denied a petition for writ of mandate and affirmed an order denying a motion to compel arbitration in a civil action. The court ordered briefing deferred pending decision in Leeper v. Shipt, Inc., S289305 (#25-91), which presents the following issues: (1) Does every Private Attorneys General Act (Lab. Code, § 2698 et seq.) (PAGA) action necessarily include both individual and non-individual PAGA claims, regardless of whether the complaint specifically alleges individual claims? (2) Can a plaintiff choose to bring only a non-individual PAGA action?

Petition for review granted; briefing deferred: 12/17/2025

See the Court of Appeal Opinion.