Williams v. Superior Court of L. A. Cnty.

Summary

The California Supreme Court considers the scope of discovery in a representative action under the Labor Code Private Attorneys General Act of 2004 (PAGA). It holds that contact information for potentially aggrieved employees is generally discoverable without requiring the plaintiff to make a preliminary showing of merit or good cause, subject to applicable objections such as privacy concerns. The court reverses the order limiting discovery to employees at the plaintiff's store and conditioning broader discovery on a deposition and showing of merit.

Holdings

1. A PAGA plaintiff may obtain contact information for employees who may have suffered the alleged Labor Code violations when the complaint alleges violations affecting employees statewide; PAGA does not justify restricting such discovery more narrowly than comparable discovery in representative class actions.
2. A party propounding interrogatories need not establish good cause, prove the merits of the action, demonstrate personal standing, or establish a uniform companywide policy as a condition of obtaining relevant information through interrogatories.
3. An objection that interrogatory discovery is unduly burdensome must be supported by evidence showing the quantum of work required; absent such evidence, the trial court may not deny statewide discovery based solely on the number of employees or require merits proof as a substitute.
4. Employee privacy interests do not justify a complete bar to disclosure of contact information in this PAGA action; disclosure may be subject to protective measures such as a Belaire-West notice and an opportunity to opt out.
5. A party seeking discovery of private information is not automatically required to establish a compelling interest or compelling need; that heightened standard applies only to obvious invasions of interests fundamental to personal autonomy. Cases requiring a compelling interest or compelling need in every private-information discovery dispute are disapproved to that extent.

Questions Presented

1. Whether a PAGA plaintiff may obtain statewide contact information for potentially aggrieved employees through interrogatories without first showing good cause or proving the merits of the underlying claims.
2. Whether the request was overbroad or unduly burdensome under California's discovery statutes.
3. Whether employee privacy interests justified a complete bar to disclosure or required a heightened compelling-need showing.
4. Whether California courts may require a PAGA plaintiff to submit to a deposition or establish a companywide policy or personal standing before obtaining discovery.

Disposition

reversed_and_remanded