Zimmerman v. Wells Fargo Bank, N.A. CA4/3
Joyce Zimmerman appeals from a judgment following entry of a summary judgment in favor of Wells Fargo Bank, N.A., on her claim for civil penalties under the Labor Code Private Attorneys General Act of 2004 (Lab. Code, § 2698 et seq.) (PAGA). The trial court granted summary judgment based on Wells Fargo’s contention the general release of claims, given by Zimmerman as part of an employment separation agreement, included a waiver of her right to bring a claim under PAGA. Zimmerman argues the court erred because her waiver of claims against Wells Fargo extended only to whatever claims she had as an individual, and did not include her distinct right to act in a representative capacity under PAGA. We agree, although we base our conclusion on a somewhat different analysis than the one advanced by Zimmerman.
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