Without deciding whether it is possible for an employee to bring only a representative and not an individual PAGA claim, this decision holds that plaintiff’s complaint sought to do just that and so escaped the reach of the employer’s arbitration clause (See Adolph v. Uber Technologies, Inc. (2023) 14 Cal.5th 1104; Balderas v. Fresh Start Harvesting, Inc. (2024) 101 Cal.App.5th 533.)  The decision holds that the legal viability of a representative only PAGA claim cannot be raised on a motion to compel arbitration but must be raised on demurrer or other pleading motion instead.  The decision disagrees with the reasoning in Leeper v. Shipt, Inc. (2024) 2024 WL 5251619 stating that even if PAGA requires an individual PAGA claim as a required component of a representative PAGA claim, that doesn’t mean that a plaintiff who has carefully alleged he isn’t bringing an individual PAGA claim is in fact doing so.  Defective complaints are filed all the time.  Courts don’t read allegations into them even when they are legally required.