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Ibarra v. Chuy & Sons Labor, Inc. (Cal. Ct. App., June 18, 2024, No. 2D CIV. B329899)

The Appellate Case

Plaintiff was employed as an hourly non-exempt worker by defendants Chuy & Sons Labor, Inc., Infinite Herbs, LLC, Baby Root Farms, and G.J. Farms, Inc. (“Employers”). Chuy is a farm labor contractor that provides labor to various client growers. The remaining three Employers are client growers. Plaintiff brought claims for civil penalties on behalf of herself and other aggrieved employees against Employers under California’s Labor Code Private Attorneys General Act of 2004 (“PAGA”).

In her pre-litigation PAGA notice to the Labor & Workforce Development Agency, Plaintiff alleged that all four Employers committed numerous wage and hour violations against her and other “aggrieved employees” described as “all other current and former non-exempt employees of Employers in the State of California during the last four years.” The trial court dismissed Plaintiff’s case on the purported ground that her notice did not further define the group of “aggrieved employees.” Plaintiff appealed and the Court of Appeal reversed. In a published decision, the Court of Appeal agreed with Plaintiff that the PAGA notice requirement did not require a more specific description of “aggrieved employees.”

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