Review granted in UCL/PAGA case: Arias v. Superior Court

Yesterday, the Supreme Court issued a "grant and hold" order in Arias v. Superior Court (Angelo Dairy), no. S155965.

As I explained in my original post on this case, the Court of Appeal's opinion contained two holdings of note: (1) Prop. 64 did not change the rules governing associational standing in UCL cases; and (2) the Labor Code Private Attorneys General Act ("PAGA") (Lab. Code §§ 2698 et seq.) authorizes a representative action, similar to a pre-Prop. 64 UCL representative action, without formal class certification. See Arias v. Superior Court, 153 Cal.App.4th 777 (2007). I haven't seen the briefing, and the statement of issues presented has not yet been posted on the Supreme Court's site, but it's reasonable to guess that Amalgamated Transit Union v. Superior Court (First Transit), no. S151615, which also addressed "associational standing" and PAGA, is the lead case here. Pursuant to Rule of Court 8.1105(e)(1), the Court of Appeal's opinion in Arias may no longer be cited.