Lyft, Inc. v. Million Seifu

This case involves the preemptive effect of the Federal Arbitration Act (FAA) on state-law employment claims brought under California’s Private Attorneys General Act (PAGA). Two Terms ago, applying the FAA, this Court divided PAGA claims subject to an arbitration agreement into two new categories of claims: “individual” claims and “non-individual” claims. Viking River Cruises, Inc. v. Moriana, 596 U.S. 639, 662 (2022). The Court directed the arbitration of individual claims and the dismissal of non-individual claims. Id. at 663. The Court’s holding that non-individual claims are to be dismissed quickly became a dead letter in California. In Adolph v. Uber Techs., Inc., the California Supreme Court held that non-individual claims should be stayed or litigated in court, not dismissed. 532 P.3d 682, 685–86 (Cal. 2023). Lower courts in California have followed this approach (including here in Lyft’s case) and have bypassed this Court’s disposition and reasoning in Viking River. But some federal district courts have applied Viking River and dismissed non-individual claims. The question here is whether—in deviating from this Court’s direction to dismiss non-individual claims—California courts have violated the FAA and this Court’s application of the FAA in Viking River. (The question here embraces the question presented in Uber Techs., Inc. v. Gregg, No. 23–645 (U.S. filed Dec. 12, 2023).)