{"id":361,"date":"2026-01-08T12:00:00","date_gmt":"2026-01-08T12:00:00","guid":{"rendered":"https:\/\/california.shuster.info\/?p=361"},"modified":"2026-01-08T12:00:00","modified_gmt":"2026-01-08T12:00:00","slug":"shanley-tracy-logistics-ed-cal-compels-arbitration-individual-paga-claim","status":"publish","type":"post","link":"https:\/\/california.shuster.info\/?p=361","title":{"rendered":"Shanley v. Tracy Logistics \u2014 E.D. Cal. Compels Arbitration of Individual PAGA Claim and Stays Representative Claim"},"content":{"rendered":"
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Case<\/dt>\n
Shanley v. Tracy Logistics LLC<\/dd>\n
Court<\/dt>\n
U.S. District Court \u2014 Eastern District of California<\/dd>\n
Date Decided<\/dt>\n
2026-01-08<\/dd>\n
Docket No.<\/dt>\n
2:23-cv-02586-DC-JDP<\/dd>\n
Status<\/dt>\n
Unreported \/ Non-Citable<\/dd>\n
Topics<\/dt>\n
PAGA, Private Attorneys General Act, Federal Arbitration Act, Adolph v. Uber, Iskanian, Viking River Cruises, transportation worker exemption<\/dd>\n<\/dl>\n<\/div>\n

Background<\/h2>\n

The plaintiff, Travis Shanley, worked as an order selector at a Stockton, California facility operated by Tracy Logistics LLC, a subsidiary of nationwide grocery wholesaler C&S Wholesale Grocers. When he was hired in May 2022, the plaintiff signed two arbitration agreements \u2014 the C&S Mutual Arbitration Agreement and the Tracy Mutual Voluntary Arbitration Agreement. Both included class and representative action waivers.<\/p>\n

In September 2023, the plaintiff filed a representative action in San Joaquin County Superior Court under California’s Private Attorneys General Act (PAGA), Labor Code section 2698 et seq. The PAGA cause of action alleged a long list of underlying Labor Code violations, including failure to pay minimum wages, overtime, sick leave, meal and rest break premiums, expense reimbursement, and timely wages, plus failure to provide accurate wage statements. The defendants removed the case to federal court and moved to compel arbitration of the plaintiff’s individual PAGA claim and stay the representative claim.<\/p>\n

The case sits at the intersection of important federal and state Supreme Court decisions about PAGA arbitration: Iskanian v. CLS Transportation (2014, prohibiting wholesale waivers of PAGA), Viking River Cruises v. Moriana (2022, allowing arbitration of individual PAGA components under the Federal Arbitration Act), and Adolph v. Uber Technologies (2023, holding that compelling individual PAGA claims to arbitration does not strip a plaintiff of standing to pursue representative PAGA claims in court).<\/p>\n

The Court’s Holding<\/h2>\n

The court granted the motion to compel arbitration of the plaintiff’s individual PAGA claim and stayed the representative PAGA claim pending the outcome of arbitration. The arbitration agreements clearly required individual arbitration of covered claims and contained ‘savings and conformity’ clauses providing that any class, collective, or representative claim that could not be arbitrated would be filed in court.<\/p>\n

The court rejected the plaintiff’s argument that, even if the Federal Arbitration Act did not apply (an argument premised on the transportation-worker exemption under 9 U.S.C. \u00a7 1), the second rule of Iskanian \u2014 barring the splitting of individual and representative PAGA claims \u2014 survives Adolph and forecloses sending the individual claim to arbitration. The court relied on the California Supreme Court’s holding in Adolph that ‘a PAGA action remains one action’ even when its individual component is compelled to arbitration; sending the individual claim to arbitration and staying the representative claim does not constitute prohibited splitting under California law.<\/p>\n

The court was unpersuaded by the plaintiff’s reliance on a Northern District of California decision (Lopez v. Thyssenkrupp Supply Chain Services), explaining that the Lopez court provided no analysis of the issue. The court noted that the Ninth Circuit subsequently affirmed Lopez but did not address the splitting question. Because Adolph supplies the controlling state-law rule and treats the bifurcated action as a single proceeding, the court found no conflict with California law and granted arbitration.<\/p>\n

The order requires the parties to submit joint status reports every ninety days during arbitration and within fourteen days of completion of arbitration proceedings.<\/p>\n

Key Takeaways<\/h2>\n