PAGA Representative Actions Remain Alive and Kicking

Wage and Hour/Labor Law Update: The California Supreme Court's 2014 decision on Iskanian v. CLS Transportation Los Angeles, LLC -- which held that agreements to waive the right to bring Private Attorney General Act of 2004 representative actions in any forum are unenforceable -- remains controlling authority notwithstanding the U.S. Supreme Court's 2018 opinion in Epic Systems Corp. v. Lewis. (See, Correia v. NB Baker Electric, Inc. (2019 S.O.S. 872).) In short, courts are still bound by the holding in Iskanian.