Appeals Court in California Clarifies that Plaintiff in PAGA Case Must File a Timely Individual Claim
On April 22, 2025, the Second Appellate District for the California Courts of Appeal issued an important rule in a Private Attorneys General Act (PAGA) case. In Williams v. Alacrity Solutions Group, LLC, the appellate court determined that an employee must file a timely individual claim in order to be eligible to file a PAGA case. The decision has important implications for employers in our state. Here, our California employment lawyer provides an overview of the key points.
Case Review: Williams v. Alacrity Solutions Group, LLC
The Facts
Corbin Williams served as an insurance adjuster for a company called Alacrity Solutions Group, LLC from 2014 until his January of 2022. During his tenure, Mr. Williams argues that he routinely worked 84-hour weeks without receiving the legally mandated overtime compensation. That is a violation of California law. Over a year after his employment ended (March of 2023), Mr. Williams filed a notice with the California Labor & Workforce Development Agency (LWDA) expressing his intent to initiate a Private Attorneys General Act (PAGA) action. Soon after, he filed a lawsuit seeking civil penalties on behalf of other current and former employees. The defendant (employer) countered that the claim was time-barred.
A Note on PAGA: The PAGA is a California law that allows employees to file lawsuits on behalf of the state for Labor Code violations committed by their employers for themselves and other “aggrieved” employees. It effectively deputizes private citizens (workers) to seek civil penalties that would otherwise be pursued by state labor enforcement agencies.
The Legal Issue
The central legal question in this case was whether a former employee—whose own Labor Code violations are time-barred as a matter of law—can pursue a PAGA claim solely on behalf of other aggrieved employees. On review, the trial court held that under PAGA, a plaintiff must have personally suffered at least one Labor Code violation within the one-year statute of limitations to maintain a representative action. Since the plaintiff’s employment ended more than a year before he filed the PAGA notice, his individual claims were untimely and the PAGA case could not move forward. Mr. Williams filed an appeal. However, the appellate court affirmed the trial court’s decision. It found that a PAGA claim is time-barred unless the individual lead plaintiff has a timely claim.
The Implications for Employers
This decision reinforces the requirement that PAGA plaintiffs must have timely individual claims to proceed with representative actions. For employers, this ruling provides a strategic defense against PAGA lawsuits filed by former employees whose own claims fall outside the statutory period. The decision also demonstrates the importance of keeping accurate, comprehensive records.
Contact Our California PAGA Lawyer for Employers Today
At Sloat Law Group, APC, our California employment attorney provides solutions-focused guidance and support for employers. If you have any questions about PAGA, we are here to help. Contact us today for a fully private, no obligation consultation. We provide employment representation to employers in Coachella Valley, Riverside County, and statewide in California.
Source:
law.justia.com/cases/california/court-of-appeal/2025/b335445.html
