PAGA Action for Meal Break Violations Not Pre-Empted by Federal Law

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​A United Airlines mechanic can proceed with his Private Attorneys General Act (PAGA) lawsuit seeking civil penalties for alleged violations of California’s meal break requirements, a California appeals court held.

The trial court said the action was pre-empted by the federal Railway Labor Act (RLA) because the court would have to interpret the parties’ collective bargaining agreement (CBA). But the appeals court disagreed.


The plaintiff was employed as a mechanic at

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