Finally, a common sense ruling.
After settling a class action lawsuit against temporary staffing agency, workers brought wage and hour putative class action raising identical claims against the client-company where they had been placed to work. The Court of Appeal held that:
1. agency and client-company were in privity for purposes of wage and hour actions, and thus settlement in prior action was res judicata against workers;
2. client-company was agent of agency with respect to payment of workers, and thus was released party under settlement agreement in prior wage and hour action against agency.
The subject underlying release included Civil Code 1542 language and released any PAGA claims. The issue was the release did not define the employer released broad enough, it only said temp Company, its parent, subsidiaries, officers, agents, successors, employees.