Ibarra v. Chuy & Sons Labor, Inc., 102 Cal. App. 5th 874 (2024)

The trial court dismissed Edelmira Ibarra’s action under the Private Attorneys General Act of 2004 (“PAGA”) on the ground that Ibarra failed to comply with PAGA’s prefiling notice requirements. Ibarra’s notice identified four named defendants who employed Ibarra from January 2021 to July 2021 and alleged that all four defendants committed numerous wage and hour violations against her “and all other current and former non-exempt employees of Employers in the State of California during the last four years.” Defendants argued that the prelitigation notice did not clearly identify the “aggrieved employees” at issue in the lawsuit. The Court of Appeal reversed the trial court’s dismissal, holding that the Labor Code does not specify that “aggrieved employees” be defined in a particular way. Instead, the prefiling notice must be specific enough that the Labor Workforce and Development Agency and any defendants can understand the factual basis for the alleged violations. Under this standard, Ibarra’s notice was sufficient.