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California Court Addresses Class Certification, PAGA, and Preemption in Trucking Litigation
On December 11, 2025, the California Court of Appeal, Third Appellate District, issued a partially published decision in Dieves v. Butte Sand Trucking Company involving a truck driver’s claims against his former employers for alleged violations of California labor law.
The appellate court affirmed in part and reversed in part the trial court’s rulings on class certification, the manageability of Private Attorneys General Act (PAGA) claims, and the applicability of federal preemption under the Motor Carrier Safety Act.
The decision provides significant guidance on the standards for class certification in wage and hour cases, the limits of trial court authority to strike PAGA claims for manageability, and the scope of federal preemption of California’s meal and rest break rules for commercial drivers.
The appellate court affirmed in part and reversed in part the trial court’s rulings on class certification, the manageability of Private Attorneys General Act (PAGA) claims, and the applicability of federal preemption under the Motor Carrier Safety Act.
The decision provides significant guidance on the standards for class certification in wage and hour cases, the limits of trial court authority to strike PAGA claims for manageability, and the scope of federal preemption of California’s meal and rest break rules for commercial drivers.
