Employment Litigation · Primary-source case analysis

Estrada: A Meaningful Defense Did Not Require Unlimited Witness Testimony

By Aneeta Mishra and Timothy Chan

Published April 13, 2026 · Updated October 18, 2026

Decision: Estrada v. Royalty Carpet Mills, Inc., No. S274340 (Cal. Jan. 18, 2024).

Estrada v. Royalty Carpet Mills, Inc., No. S274340 (Cal. Jan. 18, 2024), did not give either side an unlimited witness list. While rejecting an inherent power to dismiss PAGA claims for manageability alone, the Court preserved a meaningful opportunity to present defenses and the court’s authority to control evidence. Royalty had not shown that the proposed retrial would deny that opportunity.

The trial court had not barred the employer’s additional witnesses

Royalty presented two former employees and an expert at the initial trial. The trial court did not prohibit it from calling additional witnesses; only after the evidence closed did the court strike the non-individual meal-period PAGA component as unmanageable. Those facts undermined the claim that retrial would necessarily deny a meaningful defense. Estrada, slip op. at 39–40.

A meaningful defense was not an unlimited employee-by-employee trial

The Court agreed that a PAGA defendant must have an opportunity to prove affirmative defenses. It rejected the further proposition that this always requires testimony from every allegedly aggrieved employee. A defendant must be able to challenge the plaintiffs’ proof, including a statistical model, but reasonable limits on the method of presenting evidence do not necessarily violate due process. Estrada, slip op. at 37–39.

The limits applied to plaintiffs as well

Plaintiffs likewise had no unfettered right to present unlimited witnesses. The opinion explained that courts could limit evidence and use appropriate case-management techniques; a plaintiff still had to prove violations efficiently. The court could also issue ordinary substantive rulings where allegations were too broad or unsupported. Permission to maintain a PAGA claim was not permission to bypass proof. Estrada, slip op. at 40 n.34, 41–43.

The Court reserved a genuine constitutional last-resort question

The Court did not decide whether a demonstrated due-process problem could ever support striking a PAGA claim. Footnote 35 distinguished that hypothetical narrow last-resort authority from broad dismissal for convenience. It affirmed the Court of Appeal’s reversal of the manageability dismissal and remand for a new PAGA trial; it did not award all requested penalties. This January 2024 decision addresses inherent authority, not every statutory case-management power governing a present action. Estrada, slip op. at 40–41 & n.35, 44–45.

Key takeaways

• Identify the defense and the particular evidence needed to present it.
• Explain how a proposed limit would affect that evidence, rather than demanding unlimited witnesses.
• If statistical proof is proposed, preserve a meaningful opportunity to challenge it.
• Distinguish case-management limits, failure of proof, and an asserted constitutional violation.