Cal. Court of Appeals Affirms Trial Court Dismissal of PAGA Claim Where Plaintiff Did Not Suffer Violation Within 1-Year Statute of Limitations

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On 4/22/25, in Williams v. Alacrity Solutions Group, LLC, the California Court of Appeals affirmed the trial court's dismissal of a "headless" lawsuit brought under the California Private Attorneys' General Act of 2004 (PAGA) because the plaintiff filed the case outside the one (1) year statute of limitations. The Court disregarded Plaintiff's argument that he was only alleging claims on behalf of other "aggrieved employees" that were within the one (1) year statute of limitations. The Court held that the statute of limitations for a PAGA claim is tied to the PAGA plaintiff's own individual claim, not his representative claim. In other words, a PAGA plaintiff must bring a PAGA action within one year of the last Labor Code violation he personally suffered.

https://www4.courts.ca.gov/opinions/documents/B335445.PDF

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