Rodriguez v. Packers Sanitation Services

CourtCalifornia Court of Appeal
DecidedFebruary 26, 2025
DocketD083400
StatusPublished

This text of Rodriguez v. Packers Sanitation Services (Rodriguez v. Packers Sanitation Services) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rodriguez v. Packers Sanitation Services, (Cal. Ct. App. 2025).

Opinion

Filed 2/26/25

CERTIFIED FOR PUBLICATION

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

JOSE A. PARRA RODGRIGUEZ, D083400

Plaintiff and Respondent,

v. (Super. Ct. No. ECU002252)

PACKERS SANITATION SERVICES LTD., LLC,

Defendant and Appellant.

APPEAL from an order of the Superior Court of Imperial County, Jeffrey B. Jones, Judge. Affirmed. Fisher & Phillips, Adam F. Sloustcher, Megan E. Walker, Philip G. Simpler and Julia A. Sherwood for Defendant and Appellant. Sullivan & Yaeckel Law Group, William B. Sullivan, Eric K. Yaeckel and Ryan T. Kuhn for Plaintiff and Respondent.

INTRODUCTION Packers Sanitation Services Ltd., LLC (Packers) appeals an order denying its motion to compel arbitration of an action under the Labor Code Private Attorneys General Act of 2004 (PAGA) (Lab. Code,1 § 2698 et seq.) brought by Jose A. Parra Rodriguez (Parra). Packers contends the trial court erred by failing to compel Parra to arbitrate the individual component of his PAGA claims. Parra responds that he has forgone individual relief and his PAGA claims lack an individual component. We affirm. BACKGROUND Packers is a food safety solutions company that employed Parra in California from April 2019 to July 2021. In February 2022, Parra—acting “in a Representative Capacity only”—filed a complaint against Packers for civil penalties under PAGA based on violations of the Labor Code and California Code of Regulations, including provisions dealing with overtime and meal and rest period requirements. Parra alleged Packers committed these violations against Parra “and all other aggrieved employees.” In March 2022, Packers moved to compel arbitration based on an agreement Parra assertedly signed shortly after he was hired. The agreement stated, in part, “I and the Company agree to utilize binding individual arbitration as the sole and exclusive means to resolve all disputes that may arise out of or be related in any way to my employment . . . . I and the Company each specifically waive and relinquish our respective rights to bring a claim against the other in a court of law and to have a trial by jury.” It also stated, “I agree that any claims brought under this binding arbitration Agreement shall be brought in the individual capacity of myself or the Company.” The agreement created exceptions to binding arbitration for “claims arising under the National Labor Relations Act which are brought before the National Labor Relations Board, claims for medical and disability

1 Further undesignated statutory references are to the Labor Code.

2 benefits under the California Workers’ Compensation Act, Employment Development Department claims, or other claims that are not subject to arbitration under current law.” (Italics added.) It also specified that Packers’ business involved interstate commerce such that the Federal Arbitration Act (FAA) applied. Packers filed its motion before the United States Supreme Court decided Viking River Cruises, Inc. v. Moriana (2022) 596 U.S. 639 (Viking River). Apparently anticipating that Viking River would require wholesale enforcement of contractual waivers of the right to assert representative claims, Packers argued the action had to be dismissed because it was a “PAGA claim[ ]” and in the arbitration agreement Parra had waived his right to assert “representative claims, including under PAGA.” As an alternative to dismissal, Packers asked the trial court to stay the action pending a decision in Viking River. Parra raised several arguments in opposition: He did not remember signing the arbitration agreement. To the extent he was found to have agreed to individual arbitration, his PAGA action lacked an individual component. And last, his PAGA claims fell within the agreement’s exception for claims not subject to arbitration “under current law,” because at the time the parties entered the agreement, Iskanian v. CLS Transportation Los Angeles, LLC (2014) 59 Cal.4th 348 (Iskanian) held PAGA claims were not subject to arbitration. In its reply, which was filed after Viking River was decided, Packers disputed Parra’s interpretation of “current law.” It also argued that under Viking River Parra’s “individual PAGA claim” had to be compelled to arbitration and “any remaining non-individual PAGA claims” had to be

3 dismissed. Packers, however, did not address Parra’s assertion that his PAGA claims had no individual component. The trial court held an evidentiary hearing during which the parties presented conflicting evidence on the genuineness of the electronic signature on the arbitration agreement. After the hearing, the court denied the motion in a tentative ruling and an amended statement of decision. Although it found Parra electronically signed the agreement, it interpreted “current law” to mean the law as it stood in 2019, when the parties entered the agreement. The court reasoned that in 2019, PAGA claims “whether individual or representative” were not subject to arbitration under Iskanian, supra, 59

Cal.4th 348.2 It concluded the parties therefore had not “agreed to arbitrate PAGA claims at all.” (Italics omitted.) It then issued a minute order stating it “enter[ed] judgment” in favor of Parra and the “petition [to compel arbitration] is denied.”

2 Iskanian held that an employee’s right to bring a PAGA action was “unwaivable” and that the rule against PAGA waivers was not preempted by the FAA. (Iskanian, supra, 59 Cal.4th at pp. 383, 384.) Iskanian also rejected the employer’s argument that a PAGA waiver could be upheld if it only waived the employee’s right to bring a PAGA claim on behalf of others while preserving the employee’s right to bring such a claim on his own behalf. (Iskanian, at pp. 383–384.) “Appellate courts interpreted this aspect of Iskanian ‘as prohibiting splitting PAGA claims into individual and nonindividual components to permit arbitration of the individual claims.’ ” (Nickson v. Shemran, Inc. (2023) 90 Cal.App.5th 121, 128 (Nickson).) “Based on Iskanian, California courts refused to enforce predispute agreements to arbitrate PAGA claims.” (Ibid.) In Viking River, the United States Supreme Court declared that the FAA preempted “Iskanian’s rule that PAGA actions cannot be divided into individual and non-individual claims.” (Viking River, supra, 596 U.S. at p. 642.)

4 DISCUSSION Packers contends the trial court erred because it incorrectly equated “current law” with Iskanian’s rule against splitting PAGA claims into their individual and non-individual components. It argues that Viking River held the Iskanian anti-splitting rule was preempted by the FAA, and preemption holdings are retroactive. In Packers’ view, Viking River simply announced how the FAA has always operated, such that its holding should be considered “current law” in 2019, when the parties entered their agreement. Packers argues that the arbitration agreement therefore requires arbitration of Parra’s individual PAGA claim. It asks us to reverse the denial of its motion and remand with instructions to compel arbitration of Parra’s individual PAGA claim and to stay his non-individual claims pending arbitration. Parra responds that Packers’ interpretation of “current law” is incorrect because the phrase is ambiguous and the ambiguity should be construed against the drafter (i.e. Packers). He also contends Packers’ characterization of his complaint is incorrect. Specifically, Packers describes Parra’s complaint as alleging causes of action under PAGA “ ‘individually and on behalf of all others similarly situated.’ ” (Italics added.) But Parra asserts this mischaracterizes his complaint and he has not brought any individual PAGA claims. He cites Balderas v. Fresh Start Harvesting, Inc.

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Bluebook (online)
Rodriguez v. Packers Sanitation Services, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rodriguez-v-packers-sanitation-services-calctapp-2025.