California Supreme Court Watch

#22-03 Turrieta v. Lyft, Inc., S271721. (B304701; 69 Cal.App.5th 955; Los Angeles County Superior Court; BC714153.) Petition for review after the Court of Appeal affirmed the judgment in a civil action. The court limited review to the following issue: Does a plaintiff in a representative action filed under the Private Attorneys General Act (Lab. Code, § 2698, et seq.) (PAGA) have the right to intervene, or object to, or move to vacate, a judgment in a related action that purports to settle the claims that plaintiff has brought on behalf of the state?

Review granted: 1/05/2022

Case fully briefed: 6/09/2022

Cause argued and submitted: 5/08/2024

Opinion filed: Judgment affirmed in full: 8/01/2024

See the Court of Appeal Opinion.

See the Petition for Review.

See the Oral Argument.

See the California Supreme Court Opinion.  (Turrieta v. Lyft, Inc. (2024) 16 Cal.5th 664.)

“We agree with the Court of Appeal [that the trial court had properly denied the intervention motions and that Olson and Seifu [Lyft drivers] lacked standing to move in the trial court to vacate the judgment or to challenge the judgment on appeal]. PAGA provides that an aggrieved employee, after complying with specified procedural prerequisites, may ‘commence a civil action’ to recover civil penalties that the LWDA may assess and collect. (§ 2699.3, subd. (a)(2)(A).) Although a PAGA plaintiff may use the ordinary tools of civil litigation that are consistent with the statutory authorization to commence an action, such as taking discovery, filing motions, and attending trial, we conclude . . . that the authority Olson seeks in this case — to intervene in the ongoing PAGA action of another plaintiff asserting overlapping claims, to require a court to consider objections to a proposed settlement in that overlapping action, and to move to vacate the judgment in that action — would be inconsistent with the scheme the Legislature enacted. This conclusion best comports with the relevant provisions of PAGA as read in their statutory context, in light of PAGA’s legislative history, and in consideration of the consequences that would follow from adopting Olson’s contrary interpretation. We therefore affirm the Court of Appeal’s judgment.”

Justice Jenkins authored the opinion of the Court, in which Chief Justice Guerrero and Justices Corrigan, Kruger, and Groban concurred.

Justice Kruger filed a concurring opinion, in which Justice Groban concurred.

Justice Liu filed a dissenting opinion in which, Justice Evans concurred.

In the news: Anderson, High court win for employers, early PAGA claimants, Daily Journal (Aug. 2, 2024).