California Employment Law Update
In a pair of companion cases, the California Supreme Court ruled on two major issues for employers facing workplace violation suits. In Arias v. Superior Court (Angelo Dairy), the Court held that employees do not need to satisfy class action requirements in order to bring an action on behalf of themselves or other "aggrieved employees" under the Labor Code Private Attorneys General Act ("PAGA"), but that they are required to meet class action requirements to bring an action on behalf of others under California's Unfair Competition Law. In Amalgamated Transit Union, Local 1756, AFL-CIO v. Superior Court (First Transit, Inc.), the Court barred unions from bringing either unfair competition or PAGA claims on behalf of their members. Taken together, the two cases give employers reason for both concern and comfort.