3/3/26
Court of Appeal, First Appellate District, Division Four
The Rule of Sorokunov v. NetApp is that an arbitration award finding that a plaintiff did not suffer individual Labor Code violations can preclude the same plaintiff from claiming standing as an "aggrieved employee" in a PAGA action based on the identical violations, under circumstances where the plaintiff fully litigated the Labor Code violations in arbitration with a final award against them.
6/5/26
Court of Appeal, First Appellate District, Division One
The Rule of Baker v. Bay Area Toll Authority is that issue preclusion bars relitigation of statute of limitations arguments that were actually litigated and necessarily decided in a prior CEQA action, even when those arguments are raised in a subsequent lawsuit based on allegedly new project components, under circumstances where the party failed to appeal the prior adverse ruling and the new allegations do not establish a genuinely different project under CEQA.