Employment Litigation · Primary-source case analysis

Williams: PAGA Discovery Is Not Limited to the Employee’s Own Worksite

By Aneeta Mishra and Timothy Chan

Published September 17, 2026 · Updated October 17, 2026

Decision: Williams v. Superior Court, No. S227228 (Cal. July 13, 2017).

Williams v. Superior Court is a July 13, 2017 California Supreme Court decision about discovery in a representative Private Attorneys General Act (PAGA) action. The employee sought contact information for other California employees allegedly affected by the same wage-and-hour practices.

Ordinary discovery principles applied

The Court rejected a special rule requiring the plaintiff to establish good cause before obtaining basic employee contact information. Relevance and the ordinary discovery statutes supplied the starting point.

The request was not confined to one store

Under the PAGA framework at issue in the 2017 case, an aggrieved employee could seek civil penalties for violations affecting the employee and others. Current claims require separate review of later statutory amendments and the actual allegations. The requested statewide contact information was relevant to identifying witnesses and developing the representative claims.

The plaintiff did not have to prove the case first

The trial court could not condition broader discovery on Williams first sitting for a deposition or producing evidence that the claims had merit. Discovery ordinarily permits a party to obtain information needed to investigate and prove the case.

Privacy required safeguards, not automatic denial

Employee contact information implicates privacy interests, but the Court explained that notice procedures and protective measures can reduce intrusion. The Court rejected an unsupported geographic bar while preserving case-specific relevance, burden, and privacy review. It reversed the Court of Appeal’s denial of relief; the decision did not guarantee disclosure of every employee record in every PAGA case.

Key takeaways

• Define the alleged Labor Code violations and the affected employee group.
• Request information tied to the representative theory and relevant period.
• Propose notice and protective-order safeguards for employee privacy.
• Do not require a merits showing that the discovery itself is intended to develop.