“The inherent power of a trial court to dismiss claims has in the past been confined to two types of situations: (1) the plaintiff has failed to prosecute diligently; or (2) the complaint has been shown to be fictitious or sham such that the plaintiff has no valid cause of action.”

💡 This shows courts have very limited authority to dismiss claims, none of which apply to legitimate but complex labor violations.

“Although the discretionary power to dismiss with prejudice has been upheld in this state, its use has been tightly circumscribed.”

💡 The Supreme Court rejects the idea that judges have broad power to strike claims they find inconvenient to manage.

“In 2003, the Legislature enacted PAGA to remedy systemic underenforcement of the Labor Code.”

💡 This explains why PAGA exists and why allowing courts to strike PAGA claims undermines the statute’s core purpose.

“Courts do not have the authority to adopt procedures or policies that conflict with statutory law. Inherent powers should never be exercised in such a manner as to nullify existing legislation or frustrate legitimate legislative policy.”

💡 The Supreme Court directly rejects judicial power to override the Legislature’s decision to authorize PAGA claims.

“PAGA is based on the Legislature’s intent to maximize the enforcement of labor laws. A legislative intent to maximize the enforcement of labor laws is in tension with the class action superiority requirement.”

💡 This explains why class action manageability standards should not apply to PAGA cases with a different statutory purpose.

“Hurdles that impede the effective prosecution of representative PAGA actions undermine the Legislature’s objectives.”

💡 The Court recognizes that procedural roadblocks like manageability dismissals sabotage the enforcement mechanism the Legislature created.

“Civil penalties recovered on the state’s behalf are intended to remediate present violations and deter future ones, not to redress employees’ injuries.”

💡 This distinction explains why PAGA cases should be evaluated differently from individual damage claims.

“PAGA suits exhibit virtually none of the procedural characteristics of class actions. A class-action plaintiff can raise a multitude of claims because he or she represents a multitude of absent individuals; a PAGA plaintiff, by contrast, represents a single principal, the LWDA, that has a multitude of claims.”

💡 The U.S. Supreme Court explained why PAGA is fundamentally different from class actions, supporting the California court’s reasoning.

“While there may be cases in which the use of a nonstatutory motion procedure to dismiss a cause of action before trial is called for, courts should be wary of such requests.”

💡 The Supreme Court warns lower courts against expanding their inherent powers to create new dismissal procedures.

“The trial court dismissed the PAGA claim seeking penalties for the alleged Dyer/Derian meal break-related violations with respect to persons other than the named plaintiffs as being unmanageable.”

💡 This describes exactly what the trial court did that the Supreme Court ruled was impermissible.

“Representative testimony, surveys, and statistical analysis, along with other types of evidence, are available as tools to render manageable determinations of the extent of liability.”

💡 Courts have multiple ways to handle complex cases without requiring individual testimony from every single affected worker.

“No case, to our knowledge, holds that a defendant has a due process right to litigate an affirmative defense as to each individual class member.”

💡 The Court rejects Royalty’s argument that due process requires individual testimony from all workers.

“We now conclude that trial courts lack inherent authority to strike PAGA claims on manageability grounds.”

💡 This is the black-letter rule established by the decision that will govern all future cases.

“Section 2699, subdivision (e)(1) links a court’s authority to assess a civil penalty to the LWDA’s authority to assess a civil penalty by specifying that a court’s authority is subject to the same limitations and conditions as those placed upon the LWDA.”

💡 This explains why courts cannot impose manageability requirements on PAGA when no such limit applies to the state agency.

“We are not persuaded by Royalty’s contention that trial courts possess a broad inherent authority to strike any type of claim, irrespective of its nature, to foster judicial economy.”

💡 The Court directly rejects the corporate argument that judges can dismiss any inconvenient case for efficiency reasons.