What “Reasonable Steps” Really Mean in 2026: How California Employers Reduce PAGA and Employment Litigation Exposure

As California employers move through 2026, one thing is clear: employment litigation—and PAGA litigation in particular—is not slowing down.

Despite the highly publicized 2024 PAGA reforms, 2025 became the largest year yet for PAGA LWDA filings. That reality has

In a July 2025 decision, the California Court of Appeal for the Fifth Appellate District ruled that so-called “headless PAGA” lawsuits are allowed—actions in which a plaintiff drops their own Labor Code claims but continues to pursue penalties on behalf of other employees under the Private Attorneys General Act (PAGA). This holding, in CRST Expedited

California employers often ask what steps they can take to prevent employment litigation. While it’s impossible to completely avoid frivolous lawsuits, employers can focus on what they can control. By regularly reviewing a few key areas, employers can significantly reduce their liability. Here are five steps to get started (hint: the most important step is

The beginning of 2025 presents an ideal opportunity for companies to perform a California employment law audit. This proactive step ensures your policies align with current regulations, your managers receive proper training, your company retains required records for the appropriate duration, and will greatly reduce potential PAGA penalties under the 2024 PAGA reform. To help

With California’s recent reforms to the Private Attorneys General Act (PAGA), employers now have an unprecedented opportunity to significantly reduce their potential liability for labor code violations. One of the most crucial changes under the reformed PAGA is the introduction of penalty caps for employers who demonstrate good faith efforts to comply with labor

On June 18, 2024, Governor Newsom announced a compromise to reform California’s Private Attorneys General Act (PAGA). This announcement follows intense negotiations prompted by a looming ballot measure to repeal PAGA this November. With PAGA cases skyrocketing and average settlements reaching $1.1 million, this reform package introduces crucial changes for California employers. Attorneys Anne McWilliams

On June 18, 2024, Governor Newsom announced that a compromise had been reached to reform California’s Private Attorneys General Act (PAGA).  The negotiations were brought about by a ballot measure to repeal PAGA this November. PAGA cases have been increasing astronomically against California employers, exposing them to huge penalties, and on average PAGA cases