Brown v. Ralphs Grocery Co.
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Plaintiff filed a representative action against her employer, Ralphs Grocery, under the Private Attorneys General Act of 2004 (PAGA). In 2009, plaintiff filed with the California Labor and Workforce Development Agency (LWDA) a notice of alleged Labor Code violations, as a condition of filing a PAGA action. Plaintiff then filed a second amended complaint alleging new violations of different Labor Code provisions not specified in her 2009 notice. In 2016, plaintiff amended her notice and filed a third amended complaint.
The Court of Appeal reversed the trial court's judgment against plaintiff and held that part of plaintiff's 2009 notice was adequate and satisfied the PAGA notice requirements under Labor Code section 2699.3, subdivision (a), and part was not and did not; plaintiff's later-added PAGA claims for violations of Labor Code provisions not alleged in the 2009 notice did not timely comply with section 2699.3's notice requirements and were time-barred; and the deficient claims and later-added claims were not saved by equitable tolling, the relation back doctrine, judicial estoppel, or waiver, except to the extent the later-added claims may relate back to the PAGA claim adequately and timely noticed in 2009.
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