In a striking development earlier this year, the Labor and Workforce Development Agency (LWDA) sent a clear message to plaintiffs’ attorneys that it will no longer tolerate vague or boilerplate Private Attorneys General Act (PAGA) claims. Last month, the agency issued a formal directive to a prominent plaintiff-side law firm, ordering amendments to over 100 PAGA notices due to a lack of factual detail. 

Historically, PAGA notices could be filed with minimal effort—sometimes with little more than a copy-paste list of alleged Labor Code violations. These bare-bones filings often left employers scrambling to decipher the claims and make strategic decisions without sufficient information. The LWDA’s new stance, demanding specificity and factual support for each alleged violation, represents a much-needed correction.  

The move follows Governor Gavin Newsom’s appointment of Todd Ratshin as Deputy Secretary for Enforcement at the LWDA late last year. Ratshin, who previously served as chief counsel for the Agricultural Labor Relations Board (ALRB), brings deep experience in agricultural labor relations and state-level labor law enforcement. 

The key takeaway for employers is that if a PAGA notice lacks detail, defense counsel may have a stronger basis to challenge it or demand amendments before expending significant time and resources in defense.