Death Knell Doctrine Applies To PAGA

In Miranda v. Anderson Enterprises, the Court of Appeal heled that a trial court’s order compelling a plaintiff to arbitrate his individual claims under the Private Attorneys General Act and dismissing the plaintiff’s representative PAGA claim was appealable. The Court stated that the “death knell” doctrine, which provides an exception to the one final judgment rule when an order allows a plaintiff to pursue individual but not class claims, applies to representative claims as well.

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