Wesson v. Staples the Office Superstore, LLCAnnotate this Case
The Court of Appeal held that trial courts have inherent authority to ensure that Private Attorneys General Act of 2004 (PAGA) claims will be manageable at trial, and to strike such claims if they cannot be managed. In this case, plaintiff filed suit against his former employer, Staples, alleging a representative claim under PAGA on behalf of himself and 345 other current and former Staples General Managers (GMs) in California. Plaintiff sought almost $36 million in civil penalties for alleged Labor Code violations, all premised on the theory that Staples had misclassified its GMs as exempt executives.
In the published portion of the opinion, the court drew on established principles of the trial courts' inherent authority to manage litigation, including ensuring the manageability of representative claims, and concluded that: (1) trial courts have inherent authority to ensure that PAGA claims can be fairly and efficiently tried and, if necessary, may strike claims that cannot be rendered manageable; (2) as a matter of due process, defendants are entitled to a fair opportunity to litigate available affirmative defenses, and a trial court's manageability assessment should account for them; and (3) given the state of the record and plaintiff's lack of cooperation with the trial court's manageability inquiry, the trial court did not abuse its discretion in striking his PAGA claim as unmanageable.