Williams v. Superior Court of L. A. Cnty., 220 Cal. Rptr. 3d 472

Background

Williams, a former Marshalls hourly employee, sued under PAGA alleging companywide failures (meal/rest breaks, wage statements, timely pay, reimbursement) affecting California nonexempt employees and seeking civil penalties on behalf of the State and aggrieved employees.
Williams served interrogatories requesting names, addresses, phone numbers, and employment histories for all nonexempt California employees (≈16,500) from Mar 2012–Feb 2014; Marshalls refused and raised overbreadth, undue burden, and privacy objections.
The trial court ordered disclosure only for Williams’s Costa Mesa store (with Belaire‑West notice and cost‑sharing) but denied statewide disclosure unless Williams first sat for a deposition and showed some merit to his claims.
The Court of Appeal denied writ relief; this Court granted review to decide the proper scope of discovery in PAGA representative actions.
The Supreme Court reversed: held that employee contact information is generally discoverable in PAGA actions absent privilege, and the trial court erred in conditioning statewide discovery on proof of merits or a deposition; privacy concerns can be managed (e.g., Belaire‑West notice/protective orders).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether contact information for other California employees is discoverable in a PAGA action	Williams: contact info is relevant to identify aggrieved employees and prove companywide violations; discovery presumptively allowed	Marshalls: request overbroad (different stores/positions); seeks thousands of private third‑party records	Held: Discoverable; complaint alleges statewide representative claims, so contact info is within Code Civ. Proc. §2017.010 scope
Whether plaintiff must show good cause or merits before interrogatories compel statewide disclosure	Williams: no pre‑discovery merits showing required; interrogatories are proper starting point	Marshalls: PAGA notice/standing requires preliminary proof before broad discovery; trial court properly conditioned disclosure on deposition/merits	Held: No heightened merits/good‑cause prerequisite for interrogatories; party resisting discovery must prove undue burden
Whether the burden of producing statewide contact info justified limiting discovery	Williams: Marshalls offered no evidence quantifying burden; alternatives (partial production, cost‑sharing) available	Marshalls: producing records for ~16,500 employees is unduly burdensome and invasive	Held: Marshalls failed to present evidentiary showing of undue burden; trial court abused discretion in denying discovery on that basis
Whether privacy rights warrant denying or conditioning disclosure (e.g., opt‑in)	Williams: privacy concerns can be mitigated with Belaire‑West notice, opt‑out, protective orders	Marshalls: constitutional privacy interest requires compelling need before disclosure; fear of retaliation supports restriction	Held: Hill framework controls; contact info is not a serious privacy invasion here; no automatic compelling‑need rule; Belaire‑West notice/protective conditions adequate

Key Cases Cited

Pioneer Electronics (USA), Inc. v. Superior Court, 40 Cal.4th 360 (contact information of potential class members generally discoverable)
Hill v. National Collegiate Athletic Assn., 7 Cal.4th 1 (privacy balancing framework; not every intrusion requires compelling interest)
Iskanian v. CLS Transportation Los Angeles, LLC, 59 Cal.4th 348 (PAGA’s remedial purpose and representative nature)
Arias v. Superior Court, 46 Cal.4th 969 (PAGA civil‑penalty structure and enforcement purposes)
Greyhound Corp. v. Superior Court, 56 Cal.2d 355 (discovery liberal construction; prefer partial limits over outright denials)
West Pico Furniture Co. v. Superior Court, 56 Cal.2d 407 (burden of justifying objections to interrogatories rests with resisting party)
Union Mutual Life Ins. Co. v. Superior Court, 80 Cal.App.3d 1 (discovery may be used to determine scope of representative claims)