C.A. 1st;
A148849

The First Appellate District reversed a judgment. The court held that a plaintiff filing suit for civil penalties under the Labor Code Private Attorneys General Act of 2004 (PAGA) does not have to satisfy the statutory requirements for a private cause of action for damages or statutory penalties.

Friant & Associates, LLC failed to include the last four digits of its employees' Social Security numbers or employee identification numbers on the employees' itemized wage statements Employee Eduardo Lopez filed suit under PAGA, seeking civil penalties for Friant's noncompliance with Labor Code §226(a)(7), which mandates the inclusion of such numbers on employee wage statements.