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In Sargent v. Board of Trustees of California State University, 2021 WL 836135 (March 5, 2021), the First Appellate District Court of Appeal ruled that while public entity employers were not entirely exempt from liability for civil penalties under the Private Attorneys General Act (“PAGA”), they could be liable only where the Labor Code provisions at issue themselves provided for civil penalties.  They could not be liable for default penalties under Labor Code § 2699(f).  The Court therefore reversed a jury award of over $2.9M in PAGA penalties against California State University.   The plaintiff in Sargent was a licensed asbestos consultant for the Sonoma State University’s (which is a part of the CSU system, and a public employer) environmental health & safety office.  Sargent alleged that he complained to his supervisor Dawson about his concerns of environmental hazards which were ignored, whereupon he informed governmental agencies about his concerns.  His allege

United statesSonoma state universityBoard of trustees california state universityFirst appellate district courtCalifornia state universityPrivate attorneys general actLabor codeCalifornia stateFair employmentHousing actAlthough sargentWhile sargentWhistleblower protection actஒன்றுபட்டது மாநிலங்களில்சோணோமா நிலை பல்கலைக்கழகம்பலகை ஆஃப் அறங்காவலர்கள் கலிஃபோர்னியா நிலை பல்கலைக்கழகம்