Wood v. Kaiser Foundation Hospitals
Annotate this CaseThe last clause of section 248.5 (e) of California’s Healthy Workplaces, Healthy Families Act of 2014 (the Act) (Labor Code, § 245 et seq.) was the focus of this appeal. Plaintiff Ana Wood filed a Private Attorney General Act of 2004 (PAGA) action against her former employer Kaiser Foundation Hospitals seeking penalties for alleged violations of the Act. The trial court sustained Kaiser’s demurrer without leave to amend, determining that a PAGA action was one brought “on behalf of the public” and since it sought only civil penalties, was prohibited by section 248.5 (e). After its independent review, the Court of Appeal reached a different conclusion: the statute’s text and history provided compelling evidence that the phrase “on behalf of the public as provided under applicable state law” in section 248.5 (e) was intended to refer to actions prosecuted under the Unfair Competition Law (UCL)—not PAGA. Accordingly, the judgment of dismissal was reversed.
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