Osuna
Osuna v. Spectrum Security Services, Inc.
Opinion
Opinion
Baltodano, J.
Filed 5/27/
CERTIFIED FOR PUBLICATION
IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA
SECOND APPELLATE DISTRICT
DIVISION SIX
EDGAR OSUNA, 2d Civ. No. B338047 (Super. Ct. No. Plaintiff and Appellant, 2023CUOE015333) (Ventura County) v.
SPECTRUM SECURITY
SERVICES, INC.,
Defendant and Respondent.
Due to the systemic underenforcement of the Labor Code, the Labor Code Private Attorneys General Act of 2004 (Labor Code, 1 § 2698 et seq.; PAGA) deputizes employees to stand in the shoes of the state to pursue civil penalties on behalf of themselves and other “aggrieved employees.” (Arias v. Superior Court (2009) 46 Cal.4th 969, 980 (Arias).) So long as they were employed by the alleged violator and personally suffered at least one Labor Code violation, aggrieved employees have standing to bring representative PAGA actions. (Kim v. Reins International
1 Statutory references are to the Labor Code. California, Inc. (2020) 9 Cal.5th 73, 81-84 (Kim).) No more is required. The Legislature recently adopted Assembly Bill No. 2288 (2023-2024 Reg. Sess.), which amended portions of section 2699. Among other changes, Assembly Bill No. 2288…