Can a court dismiss a PAGA claim for being unmanageable?

Class actions can be defeated at certification if individual questions overwhelm common ones. Employers argued the same manageability screen should apply to PAGA, and some trial courts had accepted it.

Estrada held it does not. A PAGA claim is a law-enforcement action for civil penalties rather than a class action for damages, and dismissing one solely on manageability grounds — even where the claims are complex or time-intensive — is not a power trial courts possess.

The decision is narrower than either side's summary of it. The court expressly left undisturbed other tools: limiting evidence, striking claims that are unsupported, controlling trial structure, and where appropriate reducing penalties. What it removed was the single-step dismissal.

The practical consequence for a small employer is about which lever matters. Since procedural complexity will not make a PAGA claim go away, the variable that remains within the employer's control is the underlying practice and the records that show what it actually was.