In Williams v. Alacrity Solutions Group, LLC, the California Court of Appeal affirmed the dismissal of a PAGA claim where the plaintiff failed to assert a timely individual Labor Code violation. The former employee filed the required notice with the Labor & Workforce Development Agency more than a year after leaving the company, rendering his individual claim time-barred under the one-year PAGA statute of limitations.
Attempting to proceed solely on behalf of other employees, the plaintiff argued his lack of a personal claim should not affect his standing. The court rejected this, emphasizing that even under the pre-June 2024 version of PAGA, a valid individual claim is essential to bring a representative action. The court distinguished this case from prior decisions like Kim and Adolph, noting those did not address the statute of limitations for the plaintiff’s own claims.
This ruling strengthens employer defenses against so-called “headless” PAGA claims brought by plaintiffs with no timely personal violations. Employers should scrutinize whether a named plaintiff has a valid individual claim within the limitations period, as this may support early dismissal. The decision also highlights the strategic value of compelling arbitration of the individual portion of a PAGA claim, as courts increasingly reinforce the need for plaintiffs to establish personal standing before pursuing broader representative penalties.
If you have any questions about PAGA claims or how this decision may impact your business, please contact us at info@mnklawyers.com.
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