Landmark Viking River Cruises Case: Supreme Court Decision Limits PAGA Claims
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The 2022 Supreme Court ruling in the Viking River Cruises Case significantly altered the legal landscape surrounding California's Private Attorneys General Act (PAGA). In Viking River Cruises v. Moriana, the Court concluded that individual claims under PAGA could be forced into arbitration. Importantly, the Court indicated that when individual claims go to arbitration, representative claims made on behalf of other employees would no longer have standing and must be dismissed.
Case: Viking River Cruises v. Moriana
Court: Supreme Court
Case No.: 20-1573
The Plaintiff: Viking River Cruises v. Moriana
Angie Moriana, a former employee of Viking River Cruises, filed a lawsuit under California's PAGA, alleging that the company violated several provisions of the California Labor Code. Moriana sought to represent herself and other aggrieved employees, bringing both individual and representative claims.
The Defendant: Viking River Cruises v. Moriana
Viking River Cruises contended that Moriana had signed an employment agreement mandating individual arbitration for labor disputes and explicitly waiving rights to bring class or representative actions. The company argued that the Federal Arbitration Act (FAA) required the enforcement of such arbitration agreements, thereby blocking Moriana's representative claims in court.
The Case: Viking River Cruises v. Moriana
The June 2022 Supreme Court decision was a decisive ruling that stated the FAA mandates the enforcement of arbitration agreements even in the context of PAGA claims. According to the decision, employees bound by arbitration agreements must arbitrate their individual claims and, upon arbitration, lose standing to pursue representative claims for other employees in court. However, the California Supreme Court complicated matters in 2023 by clarifying that plaintiffs could still bring representative PAGA claims in state court even if their individual claims proceeded separately through arbitration.
If you need to discuss filing a wage and hour complaint, contact Blumenthal Nordrehaug Bhowmik DeBlouw LLP. Experienced and knowledgeable employment law attorneys are ready to assist you at one of their various law firm offices in Riverside, San Francisco, Sacramento, San Diego, Los Angeles, and Chicago.
