In Raines v. Coastal Pacific Food Distributors, the Court of Appeal affirmed in part, and reversed in part, a decision by the trial court granting Defendants’ motion for summary judgment on claims brought by Plaintiff under the Private Attorneys General Act (PAGA), in both a representative and individual capacity, for failure to provide and maintain accurate wage statements. The Court reversed the lower court’s grant of summary judgment on Plaintiff’s representative PAGA claim in holding that Labor Code Section 226(a) does not require proof of injury or a knowing or intentional violation. On the other hand, the Court affirmed the grant of summary judgement as to the claim brought under Labor Code Section 226(e) in holding that an individual claim brought under PAGA for damages or statutory penalties does require proof of an injury or a knowing and intentional violation. Here, Plaintiff’s individual claim failed because although the wage statements did not provide the hourly overtime rate, that rate could be easily calculated using simple division; thus, Plaintiff suffered no injury.

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