Huff

Huff v. Securitas Sec. Servs. United States, Inc.

Good Law
23 Cal. App. 5th 745·233 Cal. Rptr. 3d 502
Court of Appeal of CaliforniaMay 23, 2018H042852California7,031 words

Opinion

lead Opinion

Grover, J.

*750 This case presents the question of whether a plaintiff who brings a representative action under the Private Attorneys General Act of 2004 (PAGA; Lab. Code, § 2698, et seq. ) may seek penalties not only for the Labor Code violation that affected him or her, but also for different violations that affected other employees. The trial court granted plaintiff Forrest Huff a new trial, reasoning that Huff's failure to prove he was personally affected by one of the multiple Labor Code violations alleged in his complaint did not preclude his action under PAGA. As we will explain, *751 we conclude that PAGA allows an "aggrieved employee"-a person affected by at least one Labor Code violation committed by an employer-to pursue penalties for all the Labor Code violations committed by that employer. We will therefore affirm the order granting a new trial.

I. BACKGROUND

Huff worked as a security guard for defendant Securitas Security Services USA, Inc. (Securitas). Securitas provides businesses with on-site security. It hires employees to work as security guards, and then contracts with its clients to provide guards for a particular location. Securitas occasionally places guards in…

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