California Court Clarifies That PAGA Claims May Proceed Without Individual Wage Allegations

You do not need to bring personal wage claims to pursue civil penalties under California’s Private Attorneys General Act (PAGA). A recent decision from the California Court of Appeals confirmed that an employee may drop individual Labor Code violations and still move forward with a representative PAGA action. This clarification affects how workers like you can pursue justice even when not seeking direct compensation.

The court’s ruling in CRST Expedited, Inc. v. Superior Court underscores how procedural strategy and timing can shape whether your case continues. If you followed PAGA’s notice requirements and filed your claim correctly, you may still have the right to continue the lawsuit on behalf of your coworkers even after your individual claims are removed.

Why Employees May Still File PAGA Actions After Dropping Personal Claims

In the CRST Expedited case, the employee originally filed a complaint alleging several wage and hour violations, including missed breaks and unpaid overtime. When the employer succeeded in dismissing the personal claims, the employee continued pursuing the PAGA portion of the case. The trial court allowed the claim to move forward.

The appellate court upheld that decision, explaining that PAGA does not require an active individual claim as long as proper procedures were followed. If you timely notify the Labor and Workforce Development Agency (LWDA), wait the appropriate period, and then file your claim in court, you may still proceed even without seeking individual damages.

What Workers Should Know About Pursuing Penalties Under PAGA

You can enforce Labor Code violations on behalf of your coworkers when the state does not act on your report. The CRST Expedited case makes clear that employers cannot shut down a case simply by removing your individual wage claim.

To avoid dismissal, your PAGA notice must comply with all requirements under the law. That includes describing the violations clearly, identifying the impacted workforce group, and waiting the appropriate time before filing suit. Courts will scrutinize whether those requirements are satisfied before allowing your case to proceed.

How This Case Shapes Employer Liability Across California Workplaces

The ruling limits employers’ ability to avoid accountability through procedural tactics. If your coworkers face similar wage violations, and you completed the required steps, the court may still hear the case even if you no longer have personal damages at issue.

This decision also strengthens the collective nature of PAGA actions. By allowing cases to proceed even when individual claims are dismissed, the court reinforces PAGA’s purpose: to empower workers to hold employers accountable for systemic violations.

Strategic Filing Decisions Can Protect You and Your Coworkers

The way your case is structured early on can determine whether your PAGA claim survives legal challenges. If your lawyer files correctly and positions the case to highlight systemic issues rather than individual harm, you may have a better chance of continuing even when employers target personal claims for dismissal.

You should work with a legal team that understands how appellate decisions like CRST Expedited affect strategy. It takes careful planning to avoid procedural missteps that could result in dismissal.

Speak with a California Employment Attorney Who Represents Workers

If you reported wage violations and want to pursue penalties under PAGA, speak with a lawyer who only represents employees. You may still have a case even if your individual claims are no longer active. Enforcement through PAGA depends on correct procedures and timing.

The Nourmand Law Firm helps employees understand their rights and pursue justice in California employment cases. Our firm does not represent employers. To discuss your potential case, call The Nourmand Law Firm at 800-700-9243. We offer free consultations to California workers who want to explore their options under PAGA and other employment laws. We are here to help you hold companies accountable for systemic Labor Code violations.