By Graham Lambert and Rochelle Calderon
June 20, 2025
Two recent decisions in the California Court of Appeal, Second Appellate District — Williams v. Alacrity Solutions Group LLC[1] and Osuna v. Spectrum Security Services Inc.[2] — have highlighted the thorniest issues in Private Attorneys General Act litigation: standing and timeliness.
Both cases involve former employees who filed PAGA claims more than one year after their employment ended, yet the courts reached opposite conclusions about whether those claims could proceed.
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