Long-time blog readers and CEN watchers will recall that for the last several years, we have been watching several cases discussing whether Private Attorneys General Act (“PAGA”) claims may be stricken as unmanageable. First, in the Fall of 2021, an appellate court determined that trial courts have inherent authority to strike or limit PAGA claims that could not otherwise be made manageable in order to “preserve judicial resources [and to] prevent trials from becoming excessively complex and time-consuming.” (See Wesson v. Staples the Office Superstore, LLC (2021) 68 Cal.App.5th 746). Just a few months later, a different appellate court disagreed, concluding that while a court may limit the presentation of evidence to ensure a manageable trial, courts had no authority to strike or limit PAGA claims due to unmanageability. (See Estrada v. Royalty Carpet Mills, Inc. (2022) 76 Cal. App. 5th 685.)