Domingo v. Prime Healthcare Paradise Valley LLC, 2025 WL 2649529 (nonpub. Sept. 16, 2025) rev. granted (Dec 10, 2025); S293682/D085075 Headless PAGA Action – Employment Law Weekly

Domingo v. Prime Healthcare Paradise Valley LLC, 2025 WL 2649529 (nonpub. Sept. 16, 2025) rev. granted (Dec 10, 2025); S293682/D085075 Headless PAGA Action

Phyllis W. Cheng, Esq.

ADR Services Mediator, Former Director of the Department of Fair Employment and Housing (“DFEH”)

December 10, 2025

Petition for review after affirmance of order denying motion to compel arbitration. The court ordered briefing deferred pending decision in Leeper v. Shipt, Inc., S289305, which presents the following issues: (1) Does every Private Attorneys General Act (Lab. Code, § 2698 et seq.) (PAGA) action necessarily include both individual and non-individual PAGA claims, regardless of whether the complaint specifically alleges individual claims? (2) Can a plaintiff choose to bring only a non-individual PAGA action? Review granted/holding for lead case.

Court of Appeal Decision

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