Moniz v. Adecco USA, Inc.

Summary

The California Court of Appeal, First Appellate District, Division Four, holds that Paola Correa and her counsel lack standing to challenge the judgment approving Rachel Moniz’s revised Private Attorneys General Act settlement with Adecco USA, Inc. The court concludes that the California Supreme Court’s decision in Turrieta v. Lyft altered the controlling law and foreclosed standing based solely on Correa’s status as a PAGA representative in an overlapping action. The appeals are therefore dismissed.

Holdings

1. A plaintiff in an overlapping PAGA action does not obtain standing to intervene in, move to vacate, or appeal a judgment in another PAGA action merely by virtue of serving as the state's representative or proxy.
2. The law-of-the-case doctrine did not prevent reconsideration of Correa's standing because an intervening California Supreme Court decision altered or clarified the controlling law and expressly disapproved the earlier standing analysis.
3. Correa's asserted interests in PAGA penalties, attorney's fees, costs, a service award, and remediation of Labor Code violations did not confer standing to challenge the overlapping PAGA settlement because those interests arise from or are derivative of PAGA's representative enforcement scheme and do not materially differ from the state interest rejected in Turrieta.

Questions Presented

1. Whether Correa, as the plaintiff in an overlapping PAGA action, had standing to challenge the judgment approving Moniz's settlement after the California Supreme Court's decision in Turrieta.
2. Whether the law-of-the-case doctrine prevented the court from reconsidering Correa's standing determination from the earlier appeal.
3. Whether Correa's asserted personal interests in PAGA penalties, attorney's fees, costs, a service award, and remediation of Labor Code violations supplied standing distinct from her status as a representative of the state.
4. Whether Correa's counsel had an independent personal interest sufficient to confer standing to appeal the attorney's-fee ruling.

Disposition

dismissed