A California appellate court has reversed a lower court's decision to dismiss a lawsuit alleging labor violations by a farm labor contractor and several client growers. The complaint, filed by Edelmira Ibarra in Ventura County on December 2021, accuses Chuy & Sons Labor, Inc., Infinite Herbs, LLC, Baby Root Farms, and G.J. Farms, Inc. of multiple wage and hour violations under the Private Attorneys General Act (PAGA).
Ibarra was employed as a nonexempt worker from January to July 2021 by the defendants. In September 2021, she sent a prelitigation notice to both the defendants and the Labor Workforce and Development Agency (LWDA), detailing various alleged Labor Code violations. These included inadequate staffing levels leading to excessive workloads, missed meal and rest periods without premium pay, failure to reimburse for safety equipment like gloves and masks, off-the-clock work requirements, inaccurate recording of hours worked resulting in unpaid wages, and failure to provide accurate wage statements.
The trial court initially dismissed Ibarra’s PAGA action for failing to adequately describe "aggrieved employees" in her prelitigation notice. However, upon appeal, the higher court found that the trial court had erred in its judgment. According to PAGA requirements under Section 2699.3(a)(1)(A), an employee must notify their employer and LWDA of specific Labor Code provisions allegedly violated along with supporting facts and theories but does not need to define "aggrieved employees" with precision.
The appellate court emphasized that PAGA’s prefiling notice requirement is minimal and should be interpreted liberally to promote worker protections. The ruling stated that Ibarra’s notice was sufficient as it identified four named defendants who allegedly committed numerous wage and hour violations against her and other nonexempt employees over the past four years.
Ibarra seeks civil penalties for these alleged violations on behalf of herself and all similarly situated current or former non-exempt employees of the defendants in California. Her legal representation includes Matthew J. Matern from Matern Law Group while Jamie N. Stein represents the defendants from Light Gabler law firm.
The case has been remanded back to the trial court for further proceedings consistent with this opinion. Judge Benjamin F. Coats presided over the initial trial at Ventura County Superior Court under Case ID No. 56-2021-00561438-CU-OE-VTA.