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24 California opinions name it 2 courts 2015–2026 8 in the last five years
The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Perez v. U-Haul Co. of CA 9/16/6 CA2/7green2 sentences2025(Iskanian, supra, 59 Cal.4th at 6 pp. 384-389.) It reasoned that a PAGA claim lies outside the FAA’s coverage because “the FAA aims to ensure an efficient forum for the resolution of private disputes, whereas a PAGA action is a dispute between an employer and [a] state [a]gency.” (Id. at p. 384.) Following the decision in Iskanian, California courts unanimously endorsed the view espoused in Reyes v. Macy’s, Inc. (2011) 202 Cal.App.4th 1119, 1123-1124 , that every PAGA action is a representative action on behalf of the state and that “a single representative PAGA claim cannot be split into an a 2025(Iskanian, supra, 59 Cal.4th at 6 pp. 384-389.) It reasoned that a PAGA claim lies outside the FAA’s coverage because “the FAA aims to ensure an efficient forum for the resolution of private disputes, whereas a PAGA action is a dispute between an employer and [a] state [a]gency.” (Id. at p. 384.) Following the decision in Iskanian, California courts unanimously endorsed the view espoused in Reyes v. Macy’s, Inc. (2011) 202 Cal.App.4th 1119, 1123-1124 , that every PAGA action is a representative action on behalf of the state and that “a single representative PAGA claim cannot be split into an a | 3 | 5 |
Correia v. NB Baker Elec., Inc.green2 sentences2025In addition, plaintiff concludes his briefing by telling us “the trial court ruling should be affirmed.” In these circumstances, we decline to address the arguments over section 432.6. 29 an employer and the state Agency.” (Ibid.) Cases after Iskanian have construed Iskanian to mean that “a single representative claim cannot be split into an arbitrable individual claim and a nonarbitrable representative claim.” (E.g., Correia v. NB Baker Electric, Inc. (2019) 32 Cal.App.5th 602, 625 (Correia). 2025Thus, we follow Correia and other cases that have construed Iskanian to mean that a representative claim “cannot be split into an arbitrable individual claim and a nonarbitrable representative claim.” (Correia, supra, 32 Cal.App.5th at p. 625 .) Viking River recognized as much when it described the “rule of Iskanian” as “preclud[ing] division of PAGA actions into individual and non-individual claims through an agreement to arbitrate.” (Viking River, supra, 596 U.S. at p. 662 .) As Correia also points out (Correia, at p. 625), Iskanian stated that Justice Chin “correctly observes [that] ‘every | 3 | 3 |
Lopez v. Friant & Assocs., LLCgreen2 sentences2017Our FAA holding applies specifically to a state law rule barring predispute waiver of an employee's right to bring an action that can only be brought by the state or its representatives, where any resulting judgment is binding on the state and any monetary penalties largely go to state coffers." ( Iskanian, supra , 59 Cal.4th at pp. 387-388, 173 Cal.Rptr.3d 289 , 327 P.3d 129 .) Following Iskanian , the court in Williams v. Superior Court (Pinkerton) (2015) 237 Cal.App.4th 642 , 648-649, 188 Cal.Rptr.3d 83 ( Williams ), rejected a defendant's attempt to compel arbitration of an employee's indi 2017Our FAA holding applies specifically to a state law rule barring predispute waiver of an employee's right to bring an action that can only be brought by the state or its representatives, where any resulting judgment is binding on the state and any monetary penalties largely go to state coffers." ( Iskanian, supra , 59 Cal.4th at pp. 387-388, 173 Cal.Rptr.3d 289 , 327 P.3d 129 .) Following Iskanian , the court in Williams v. Superior Court (Pinkerton) (2015) 237 Cal.App.4th 642 , 648-649, 188 Cal.Rptr.3d 83 ( Williams ), rejected a defendant's attempt to compel arbitration of an employee's indi | 3 | 3 |
Williams v. Superior Courtgreen2 sentences2025There, the court stated the second amended complaint “retained the PAGA claim from the original complaint” and that claim “sought PAGA penalties for various Labor Code violations[.]” (Id. at p. 595; see also, Williams v. Superior Court (2015) 237 Cal.App.4th 642, 649 [“case law suggests that a single representative PAGA claim cannot be split into an arbitrable individual claim and a nonarbitrable representative claim”]; Viking River, supra, at p. 654, fn. 6 .) Individual PAGA claim. 2025(Iskanian, supra, 59 Cal.4th at 6 pp. 384-389.) It reasoned that a PAGA claim lies outside the FAA’s coverage because “the FAA aims to ensure an efficient forum for the resolution of private disputes, whereas a PAGA action is a dispute between an employer and [a] state [a]gency.” (Id. at p. 384.) Following the decision in Iskanian, California courts unanimously endorsed the view espoused in Reyes v. Macy’s, Inc. (2011) 202 Cal.App.4th 1119, 1123-1124 , that every PAGA action is a representative action on behalf of the state and that “a single representative PAGA claim cannot be split into an a | 2 | 17 |
Reyes v. Macy's, Inc.green2 sentences2025(Iskanian, supra, 59 Cal.4th at 6 pp. 384-389.) It reasoned that a PAGA claim lies outside the FAA’s coverage because “the FAA aims to ensure an efficient forum for the resolution of private disputes, whereas a PAGA action is a dispute between an employer and [a] state [a]gency.” (Id. at p. 384.) Following the decision in Iskanian, California courts unanimously endorsed the view espoused in Reyes v. Macy’s, Inc. (2011) 202 Cal.App.4th 1119, 1123-1124 , that every PAGA action is a representative action on behalf of the state and that “a single representative PAGA claim cannot be split into an a 2025(Iskanian, supra, 59 Cal.4th at 6 pp. 384-389.) It reasoned that a PAGA claim lies outside the FAA’s coverage because “the FAA aims to ensure an efficient forum for the resolution of private disputes, whereas a PAGA action is a dispute between an employer and [a] state [a]gency.” (Id. at p. 384.) Following the decision in Iskanian, California courts unanimously endorsed the view espoused in Reyes v. Macy’s, Inc. (2011) 202 Cal.App.4th 1119, 1123-1124 , that every PAGA action is a representative action on behalf of the state and that “a single representative PAGA claim cannot be split into an a | 2 | 8 |
Viking River Cruises, Inc. v. Morianagreen2 sentences2025There, the court stated the second amended complaint “retained the PAGA claim from the original complaint” and that claim “sought PAGA penalties for various Labor Code violations[.]” (Id. at p. 595; see also, Williams v. Superior Court (2015) 237 Cal.App.4th 642, 649 [“case law suggests that a single representative PAGA claim cannot be split into an arbitrable individual claim and a nonarbitrable representative claim”]; Viking River, supra, at p. 654, fn. 6 .) Individual PAGA claim. 2025Thus, we follow Correia and other cases that have construed Iskanian to mean that a representative claim “cannot be split into an arbitrable individual claim and a nonarbitrable representative claim.” (Correia, supra, 32 Cal.App.5th at p. 625 .) Viking River recognized as much when it described the “rule of Iskanian” as “preclud[ing] division of PAGA actions into individual and non-individual claims through an agreement to arbitrate.” (Viking River, supra, 596 U.S. at p. 662 .) As Correia also points out (Correia, at p. 625), Iskanian stated that Justice Chin “correctly observes [that] ‘every | 1 | 3 |
Franco v. Arakelian Enterprises, Inc.green1 sentence2016“Because ‘ “every PAGA action,’ ” whether seeking penalties as to only one aggrieved employee or as to other employees as well, ‘ “is a representative action on behalf of the state” ’ [citing Iskanian], [the employee’s] individual PAGA claims are no more subject to his [arbitration] agreement than are his representative claims.” (Franco v. Arakelian Enterprises, Inc. (2015) 234 Cal.App.4th 947, 965, fn. 11 .) Cintas, on the other hand, contends that Tarantino can be compelled to arbitrate his individual PAGA claim because the employment agreement--including the arbitration clause--is governed | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in California. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Iskanian v. CLS Transportation Los Angeles, LLC
red
2 sentences2025Thus, we follow Correia and other cases that have construed Iskanian to mean that a representative claim “cannot be split into an arbitrable individual claim and a nonarbitrable representative claim.” (Correia, supra, 32 Cal.App.5th at p. 625 .) Viking River recognized as much when it described the “rule of Iskanian” as “preclud[ing] division of PAGA actions into individual and non-individual claims through an agreement to arbitrate.” (Viking River, supra, 596 U.S. at p. 662 .) As Correia also points out (Correia, at p. 625), Iskanian stated that Justice Chin “correctly observes [that] ‘every 2025(Iskanian, supra, 59 Cal.4th at 6 pp. 384-389.) It reasoned that a PAGA claim lies outside the FAA’s coverage because “the FAA aims to ensure an efficient forum for the resolution of private disputes, whereas a PAGA action is a dispute between an employer and [a] state [a]gency.” (Id. at p. 384.) Following the decision in Iskanian, California courts unanimously endorsed the view espoused in Reyes v. Macy’s, Inc. (2011) 202 Cal.App.4th 1119, 1123-1124 , that every PAGA action is a representative action on behalf of the state and that “a single representative PAGA claim cannot be split into an a | 10 | 2016–2025 |
Tanguilig v. Bloomingdale's, Inc.
green
2 sentences2019(See Williams v. Superior Court (2015) 237 Cal.App.4th 642 , 649, 188 Cal.Rptr.3d 83 [no authority to support trial court's decision to "split" PAGA claim and send question of whether the plaintiff was an "aggrieved employee" to arbitration; case law instead "suggests that a single representative PAGA claim cannot be split into an arbitrable individual claim and a nonarbitrable representative claim"]; Tanguilig v. Bloomingdale's, Inc. (2016) 5 Cal.App.5th 665 , 676-678, 210 Cal.Rptr.3d 352 [rejecting defendant's argument that court "should compel arbitration of 'the individual portion of [the 2019(See Williams v. Superior Court (2015) 237 Cal.App.4th 642 , 649, 188 Cal.Rptr.3d 83 [no authority to support trial court's decision to "split" PAGA claim and send question of whether the plaintiff was an "aggrieved employee" to arbitration; case law instead "suggests that a single representative PAGA claim cannot be split into an arbitrable individual claim and a nonarbitrable representative claim"]; Tanguilig v. Bloomingdale's, Inc. (2016) 5 Cal.App.5th 665 , 676-678, 210 Cal.Rptr.3d 352 [rejecting defendant's argument that court "should compel arbitration of 'the individual portion of [the | 2 | 2019–2019 |
Betancourt v. Prudential Overall Supply
green
1 sentence2025In Correia – a case involving interstate commerce where the FAA applied – the court agreed with other Court of Appeal cases which “have uniformly held that an employee’s predispute agreement to arbitrate PAGA claims is not enforceable without the state’s consent.” (Correia, supra, 32 Cal.App.5th at p. 621 , citing cases.)8 Correia explained: “Relying on the rationale 8 The cases Correia cited are: Julian v. Glenair, Inc. (2017) 17 Cal.App.5th 853 , 869–872; id. at p. 860 [“We hold that an agreement to arbitrate a PAGA claim, entered into before an employee is statutorily authorized to bring su | 1 | 2025–2025 |
Julian v. Glenair, Inc.
green
1 sentence2025In Correia – a case involving interstate commerce where the FAA applied – the court agreed with other Court of Appeal cases which “have uniformly held that an employee’s predispute agreement to arbitrate PAGA claims is not enforceable without the state’s consent.” (Correia, supra, 32 Cal.App.5th at p. 621 , citing cases.)8 Correia explained: “Relying on the rationale 8 The cases Correia cited are: Julian v. Glenair, Inc. (2017) 17 Cal.App.5th 853 , 869–872; id. at p. 860 [“We hold that an agreement to arbitrate a PAGA claim, entered into before an employee is statutorily authorized to bring su | 1 | 2025–2025 |
Epic Systems Corp. v. Lewis
green
2 sentences2021Among other matters the court cited authority for the proposition a single representative PAGA claim could not be split into an arbitrable individual claim and a nonarbitrable representative claim; determined Epic Systems, supra, 138 S.Ct. 1612 did not invalidate the California Supreme Court’s holding in Iskanian, supra, 59 Cal.4th 348 that an employee’s right to bring a representative PAGA action is unwaivable; and, because it was still bound by Iskanian, concluded the Representative Action Waiver was unenforceable. 2021Among other matters the court cited authority for the proposition a single representative PAGA claim could not be split into an arbitrable individual claim and a nonarbitrable representative claim; determined Epic Systems, supra, 138 S.Ct. 1612 did not invalidate the California Supreme Court’s holding in Iskanian, supra, 59 Cal.4th 348 that an employee’s right to bring a representative PAGA action is unwaivable; and, because it was still bound by Iskanian, concluded the Representative Action Waiver was unenforceable. | 1 | 2021–2021 |
Zakaryan v. Men's Wearhouse, Inc.
green
2 sentences2019(See Zakaryan , supra , 33 Cal.App.5th at p. 677 , 245 Cal.Rptr.3d 333 ["We agree with Lawson 's central holding but disagree with its subsidiary holding regarding the allocation of the 'civil penalties' recovered"].) The court did not rule on the related request for a stay of the remaining aspects of Mejia's claim, effectively denying the request. 2019(See Zakaryan , supra , 33 Cal.App.5th at p. 677 , 245 Cal.Rptr.3d 333 ["We agree with Lawson 's central holding but disagree with its subsidiary holding regarding the allocation of the 'civil penalties' recovered"].) The court did not rule on the related request for a stay of the remaining aspects of Mejia's claim, effectively denying the request. | 1 | 2019–2019 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.