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.
Kerri H. Sakaue
Associate
Baker & Hostetler LLP
Phone: (310) 820-8800
Email: ksakaue@bakerlaw.com
She represents businesses in all aspects of employment-related litigation, including wage and hour class, collective and representative actions, and state and federal litigation of wrongful termination, discrimination, harassment, retaliation and leave and accommodation claims.
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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