California Appeals Court Orders Arbitration of Individual PAGA Claims in Santana v. Studebaker Health Care Center

A California appellate court issued an important ruling on the relationship between arbitration agreements and Private Attorneys General Act (PAGA) claims in Santana v. Studebaker Health Care Center, Inc. The decision addresses how individual and representative PAGA claims should proceed when an employee has signed an arbitration agreement.

Case: J. Asencion Santana v. Studebaker Health Care Center, Inc.

Court: Court of Appeal of the State of California, Second Appellate District, Division Seven

Case No.: B343640

Decision Date: April 7, 2026

The Plaintiff: Santana v. Studebaker Health Care Center, Inc.

J. Asencion Santana filed a wage-and-hour action asserting claims under California’s Private Attorneys General Act, commonly referred to as PAGA.

PAGA allows employees to pursue certain Labor Code penalties on behalf of the State of California and other allegedly affected workers. In recent years, California and federal courts have continued to address how PAGA claims interact with arbitration agreements entered into during employment.

According to the appellate opinion, the dispute in Santana focused primarily on procedural and arbitration-related issues rather than whether underlying Labor Code violations actually occurred.

The Defendant: Santana v. Studebaker Health Care Center, Inc.

Studebaker Health Care Center, Inc. sought to compel arbitration based on an arbitration agreement between the parties.

Employment arbitration agreements remain one of the most actively litigated areas of California employment law, especially in cases involving representative labor claims under PAGA. Employers frequently argue that individual claims should proceed in arbitration, while plaintiffs often seek to maintain representative claims in court.

The appellate decision in Santana addressed how those competing procedural interests should be handled under current California law.

A History of the Case: Santana v. Studebaker Health Care Center, Inc.

The litigation reached the California Court of Appeals after the trial court denied Studebaker Health Care Center, Inc.’s petition to compel arbitration.

On April 7, 2026, the Court of Appeal for the Second Appellate District, Division Seven, reversed the lower court’s ruling.

According to the published opinion, the appellate court directed the trial court to enter a new order:

● Granting the petition to compel arbitration of Santana’s individual PAGA claims, and

● Staying the representative PAGA claim pending completion of arbitration proceedings involving the individual claims.

The opinion relied in part on the California Supreme Court’s decision in Adolph v. Uber Technologies, Inc., which continues to shape California courts’ handling of arbitration disputes involving PAGA actions.

The Main Question Being Considered: Santana v. Studebaker Health Care Center, Inc.

The central legal question involved whether individual PAGA claims could be compelled to arbitration while representative PAGA claims remained pending in court.

The appellate court examined the interaction between California PAGA law, arbitration agreements, and federal arbitration principles. The decision also addressed how courts should proceed after the California Supreme Court’s guidance in Adolph v. Uber Technologies, Inc.

Rather than deciding whether Labor Code violations occurred, the opinion focused on the procedural structure of PAGA litigation and the proper handling of arbitration-related disputes.

Why This Case Matters: Santana v. Studebaker Health Care Center, Inc.

The Santana decision is part of a growing body of California appellate rulings addressing how arbitration agreements affect representative employment claims. These rulings continue shaping litigation strategy for employers and employees throughout California.

For employers, the decision reinforces the possibility that individual individual PAGA claims may proceed in arbitration, even while representative claims remain pending. For employees, the case illustrates how representative labor actions can continue, despite arbitration proceedings involving individual claims.

The ruling also reflects the continuing influence of Adolph v. Uber Technologies, Inc. and the evolving procedural framework governing California PAGA litigation.

FAQ: Santana v. Studebaker Health Care Center, Inc.

Q: What is the Santana v. Studebaker Health Care Center case about?

A: The case involves arbitration and procedural issues connected to California PAGA wage-and-hour claims.

Q: What did the California Court of Appeals decide?

A: The appellate court reversed the trial court’s order denying arbitration and directed the lower court to compel arbitration of the individual PAGA lawsuits while pending arbitration the representative PAGA claim.

Q: What is a PAGA claim?

A: A PAGA claim allows employees to pursue certain California Labor Code penalties on behalf of the State of California and other allegedly affected workers.

Q: Did the appellate court decide whether labor violations occurred?

A: No. The opinion addressed arbitration and procedural questions rather than deciding the merits of the underlying Labor Code allegations.

Q: Why is Adolph v. Uber Technologies important to this case?

A: The appellate court relied on legal principles discussed in Adolph v. Uber Technologies, Inc. regarding the relationship between arbitration proceedings and representative PAGA claims.

If you have questions about California PAGA litigation, arbitration agreements, wage-and-hour disputes, or representative employment claims, contact Blumenthal Nordrehaug Bhowmik DeBlouw LLP. Experienced employment law attorneys are ready to help at offices in Los Angeles, San Diego, San Francisco, Sacramento, Riverside, and Chicago.