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California Court of Appeal Affirms Dismissal of PAGA Claims Based on Prior Settlement and Claim Preclusion
On November 19, 2025, the California Court of Appeal, Second Appellate District, Division Eight, issued a published decision in Brown v. Dave & Buster’s of California, affirming the dismissal of a Private Attorneys General Act (PAGA) action brought by a former employee against her employer. The court held that a prior settlement in a related PAGA action released the plaintiff’s claims and that her subsequent lawsuit alleging substantially identical claims was barred by claim preclusion, a legal doctrine that prevents parties from relitigating claims that have already been decided by a court in a final judgment.
In this era of runaway PAGA litigation, several California employers are facing multiple or serial PAGA claims alleging the same or substantially the same allegations, and this case provides needed support to help ensure that PAGA claims that are settled and released will be effective in barring later-filed claims for the same claim period.
In this era of runaway PAGA litigation, several California employers are facing multiple or serial PAGA claims alleging the same or substantially the same allegations, and this case provides needed support to help ensure that PAGA claims that are settled and released will be effective in barring later-filed claims for the same claim period.
