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Urbino v. Orkin Services of California, Inc.

Articles Discussing Case:

Who Needs the Aggregation? Ninth Circuit Rejects Combining of PAGA Penalties to Establish Minimum Amount in Controversy

Ogletree Deakins • August 26, 2013
The Ninth Circuit Court of Appeals recently issued a decision in Urbino v. Orkin Services of California, Inc., No. 11-56944 (August 13, 2013) holding that civil penalties available under California’s Private Attorneys General Act of 2004 (PAGA) may not be aggregated to establish the minimum amount in controversy of $75,000, which is required for federal diversity jurisdiction.