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California Supreme Court to Decide: Can Workers Bring “Headless” PAGA Cases?

The California Supreme Court is preparing to answer one of the biggest questions about workers’ rights in years: Can employees bring a PAGA lawsuit only on behalf of their coworkers, even if they don’t include claims for themselves?

That’s the core issue in Williams v. Alacrity Solutions Group, LLC. Their decision will directly impact how California’s Private Attorneys General Act (PAGA) can be used to enforce labor laws.

What is PAGA?

The Private Attorneys General Act (PAGA) was passed in 2004 to give workers the ability to enforce California’s labor laws when state agencies can’t.

When a company violates labor laws – whether it’s failing to pay overtime, skipping meal breaks, or ignoring safety rules – workers can file a PAGA lawsuit “on behalf of” the State of California and their coworkers. If successful, penalties are collected, with 75% going to the state and 25% going to affected employees.

PAGA has become one of the strongest tools for holding employers accountable. But it’s also become one of the most contested, with corporations trying to limit its reach at every turn.

What’s at Stake

PAGA allows workers to act as “private attorneys general” when companies break labor laws, stepping in to enforce the law if state agencies don’t have the resources.

The Supreme Court will decide two key questions:

  1. Does every PAGA case have to include both individual claims (for the worker bringing the case) and non-individual claims (for coworkers)?
  2. Or can a worker choose to bring a case only for the benefit of their coworkers (sometimes called a “headless” PAGA claim)?

Employers argue PAGA always requires both types of claims. Workers argue the law’s text and purpose are clear: it allows actions “on behalf of” others, meaning for their benefit, even if the plaintiff isn’t pursuing their own penalties.

Why This Matters for Workers

If the Supreme Court rules in favor of workers, it will:

  • Strengthen PAGA as a tool for exposing labor violations. Employees could continue filing cases to expose systemic violations, even if their own claims aren’t part of the case.
  • Close arbitration loopholes. Companies often try to force workers’ individual claims into private arbitration, slowing down or shutting down enforcement. Headless PAGA claims ensure violations can still be pursued in court.
  • Protect coworkers and the public. Even if one worker’s situation is resolved, they can still speak up for everyone else.

If the Court rules the other way, it could weaken PAGA and make it harder to hold employers accountable.

The Connection to Leeper v. Shipt

The Supreme Court has said it won’t fully brief Williams until it decides another major case: Leeper v. Shipt. Clarkson Law Firm represents the worker in Leeper, and the outcome there will set the stage for Williams.

In Leeper, the Clarkson appellate team is making the case that PAGA’s “on behalf of” language means exactly what it says – workers can enforce the law for the benefit of others, not just themselves. That argument has already won in appellate courts. In Galarsa v. Dolgen, where Clarkson also represented the worker, the Court of Appeal confirmed that headless PAGA claims are valid. The California Supreme Court now has the chance to make that the law of the land.

What’s Next

The California Supreme Court’s rulings in Leeper and Williams will shape the future of workplace protections statewide. They’ll decide whether PAGA remains the powerful enforcement tool the Legislature intended – or whether corporations can narrow its reach.

If you’re a worker who has been affected by labor law violations, reach out to us. Clarkson is here to protect workers and ensure California’s workplace protections remain strong.

The case is Williams v. Alacrity Solutions Group, Case S291199 in the Supreme Court of California.