Labor/Employment
Jan. 31, 2025
What the Leeper decision does - and doesn't - change about Balderas
California's 2nd District Court of Appeal delivers a blow to "headless" PAGA actions in Leeper v. Shipt Inc. while carefully distinguishing--but not disturbing-- a key holding in Balderas.
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Following the U.S. Supreme Court's decision in Viking River Cruises Inc. v. Moriana, 596 U.S. 639 (2022), and in a bid to avoid arbitration of their individual Private Attorneys General Act (PAGA) claims, employees have increasingly sought to bring claims under PAGA on a representative, nonindividual basis only (i.e., "headless" PAGA actions). This litigation trend was rein...
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