Galarsa v. Dolgen California, 88 Cal.App.5th 639 (2023) rev. granted, 2025 WL 3674383 (Mem) (Dec. 17, 2025); S293545/F089004 Headless PAGA Action – Employment Law Weekly

Galarsa v. Dolgen California, 88 Cal.App.5th 639 (2023) rev. granted, 2025 WL 3674383 (Mem) (Dec. 17, 2025); S293545/F089004 Headless PAGA Action

Phyllis W. Cheng, Esq.

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

December 17, 2025

Petition for review after denial of petition for writ of mandate and affirmance of order denying motion to compel arbitration. 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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