In the News: Steve Katz Publishes Article on PAGA Ambiguities in California Litigation
Constangy partner and Appellate practice group chair Steve Katz published an article, titled “Paintings, Pipes and PAGA,” in the September 2025 edition of The Journal of the Litigation Section of the California Lawyers Association.
In the article, Steve examines the slippery language at the heart of California’s Private Attorneys General Act (PAGA). He explains how conflicting uses of the terms “representative,” “individual,” and “nonindividual” have fueled sharp divides in recent appellate decisions and why the California Supreme Court has granted review in key cases to resolve this confusion.
Rather than simply recounting the caselaw, Steve points to a clearer framework proposed by the courts, which replaces ambiguous labels with more precise terminology, and shows how adopting this approach could shape the future of PAGA litigation.
To read the full article, click here.
Steve Katz is a partner in Constangy’s Los Angeles office and chair of the firm’s Appellate Practice Group. A California State Bar–certified appellate specialist, he has handled nearly 150 appeals and writs before courts nationwide, including the U.S. and California Supreme Courts. Steven represents employers in complex wage and hour and class action litigation, having defended more than 200 class, collective, and representative actions across diverse industries. His dual experience as a trial litigator and appellate advocate allows him to guide high-stakes employment cases from defense through resolution.
