Judge: Stephen P. Pfahler, Case: 20STCV04836, Date: 2025-03-18 Tentative Ruling



Case Number: 20STCV04836    Hearing Date: March 18, 2025    Dept: 68

Dept. 68

Date: 3-18-25

Case: 20STCV04836

Trial Date: Not Set

 

LIFT STAY

 

MOVING PARTY: Plaintiff, Manuel Reyes

RESPONDING PARTY: Defendants, Aerotek, Inc., et al.

 

RELIEF REQUESTED

Motion to Lift Stay

 

SUMMARY OF ACTION

On February 6, 2020, Plaintiff Manuel filed an 11 cause of action wage and hour, wrongful termination and violation of Business and Professions Code complaint, which included a cause of action identified as Private Attorneys General Act (PAGA). On April 1, 2020, Plaintiff filed a single cause of action PAGA complaint. On May 21, 2020, Plaintiff filed a second amended PAGA complaint without any apparent order or stipulation allowing for leave. On August 17, 2020, Defendants Dispending Dynamic International and Aerotek, Inc. answered the “third” amended complaint. On September 9, 2020, the court entered the stipulation to file the third amended complaint. On September 16, 2020, Plaintiff filed the third amended PAGA complaint.

 

On October 25, 2022, the court granted the Aerotek motion to compel arbitration as to the individual cause of action, deferred consideration of dismissal of the representative PAGA pending either resolution of the individual PAGA claims or the California Supreme Court ruling on Adolph v. Uber Technologies, and stayed the entire case.

 

RULING: Denied without Prejudice.

Plaintiff Manuel Reyes moves to lift the stay in order to proceed with the representative PAGA claims, in that the subject representative claims are not subject to arbitration review. Defendant Dispending Dynamics International, Inc. (DDD) filed an opposition on grounds that in the dismissal of the individual PAGA claims in arbitration, said dismissal impacts the right to proceed on any representative PAGA claims as an “aggrieved employee.” At a minimum, DDD requests the court address the motion to confirm the arbitration award before allowing Plaintiff a renewed opportunity to proceed on said claims. Defendant Aerotek, Inc. (Aero) also opposes the motion on grounds of waiting for confirmation of the arbitration award. Like DDD, Aero challenges the right to proceed on the representative PAGA claim as an individually barred Plaintiff. The court electronic filing system shows no reply on file at the time of the tentative ruling publication cutoff.

 

“If a court of competent jurisdiction, whether in this State or not, has ordered arbitration of a controversy which is an issue involved in an action or proceeding pending before a court of this State, the court in which such action or proceeding is pending shall, upon motion of a party to such action or proceeding, stay the action or proceeding until an arbitration is had in accordance with the order to arbitrate or until such earlier time as the court specifies.

 

“If an application has been made to a court of competent jurisdiction, whether in this State or not, for an order to arbitrate a controversy which is an issue involved in an action or proceeding pending before a court of this State and such application is undetermined, the court in which such action or proceeding is pending shall, upon motion of a party to such action or proceeding, stay the action or proceeding until the application for an order to arbitrate is determined and, if arbitration of such controversy is ordered, until an arbitration is had in accordance with the order to arbitrate or until such earlier time as the court specifies.

 

“If the issue which is the controversy subject to arbitration is severable, the stay may be with respect to that issue only.”

 

(Code Civ. Proc., § 1281.4.)

 

Plaintiff relies on the discretionary standard interpreted by a court requiring a trial to “stay the action or proceeding until an arbitration is had in accordance with the order to arbitrate or until such earlier time as the court specifies.” (MKJA, Inc. v. 123 Fit Franchising, LLC (2011) 191 Cal.App.4th 643, 660.) The MKJA court held that a stay should remain intact pending full resolution of the arbitration, unless an action is potentially “severable,” meaning said arbitrable issue is removed from the scope of arbitration. (Id. at pp. 660-661.) On this basis Plaintiff invites the court to essentially preemptively consider the impact of the “procedural dismissal” to the action based by the arbitrator on the as yet addressed motion to confirm the arbitration order.

 

The PAGA claim in the third amended complaint is identified as a representative action only, with no individual claim. On May 1, 2023, the arbitrator dismissed any individual PAGA claim held by Plaintiff on grounds of the statute of limitations. [Declaration of Harout Messrelian, ¶ 3 Ex. 1: Final Award.] Plaintiff cites the most recent case law regarding the state of PAGA claims following the Viking River Cruises v. Mariana (2022) 596 U.S. 639 and Adolph v. Uber Technologies, Inc. (2023) 14 Cal.5th 1104 cases. The Second Appellate District now recognizes the right of an individual to bring a representative PAGA action even if the named plaintiff lacks an individual claim. (Balderas v. Fresh Start Harvesting, Inc. (2024) 101 Cal.App.5th 533, 539 accord Adolph v. Uber Technologies, Inc., supra, 14 Cal.5th at p. 1120.)

 

While it is represented Plaintiff submitted no opposition to the petition to confirm the arbitration award, the court docket only shows a motion to confirm arbitration award currently scheduled for May 28, 2025. [See Declaration of Nicole Roysdon, ¶ 10.] Whether Plaintiff elects to file an opposition to the “motion,” never objected to the arbitrator order, or improperly delayed opposing the petition to confirm the arbitration order remains for consideration at the May 28, 2025, hearing date. The court declines to offer any advisory opinion on a motion not before the court.

 

The court therefore finds no basis for a lift of the stay at this time. “Trial courts generally have the inherent power to stay proceedings in the interests of justice and to promote judicial efficiency.” (Freiberg v. City of Mission Viejo (1995) 33 Cal.App.4th 1484, 1489; see OTO, L.L.C. v. Kho (2019) 8 Cal.5th 111, 141 [“[A] court ordinarily has inherent power, in its discretion, to stay proceedings when such a stay will accommodate the ends of justice”]; Cooper v. Superior Court In and For Los Angeles County (1961) 55 Cal.2d 291, 301; Bailey v. Fosca Oil Co. (1963) 216 Cal.App.2d 813, 817.)

 

Given the state of the pending arbitration award, and the potential required considerations said order will warrant, the court defers consideration unless and until a review of the arbitrator’s award is complete and an order entered. The court declines to engage in a premature review of the impacts for the expedient convenience of Plaintiff. The court will consider a limited lift of the stay for purposes of considering the motion to confirm arbitration as entirely consistent within the meaning of Code of Civil Procedure section 1281.4, which may or may not lead to the lifting of the stay of the entire action at that time. Should the court lift the stay to the entire action at the time, however, nothing in consideration of the motion for order confirming the arbitration award will necessarily, once again, invite consideration of the right to proceed or not proceed with the aggrieved party claims as presented by Plaintiff. In other words, the court will rule on the motion to compel arbitration and the stay, as a form of necessity, but any challenge to the status of Plaintiff may still require a later filed motion actually providing notice of a request to either dismiss the claim, with an opposition allowing it to proceed under PAGA guidelines.

 

The motion to lift the stay is therefore DENIED without prejudice pending the May 28, 2025, motion to confirm the arbitration award.

 

The motion to confirm arbitration award remains scheduled for May 28, 2025.

 

Plaintiff to provide notice.