Seyfarth Shaw LLP | www.seyfarth.com Litigating CA Wage & Hour Class and PAGA Actions (24th Edition) 187 teaches that whether in an individual settlement, or even class settlement, employers should insist on specific language waiving specific claims against specific parties. Otherwise, employers might not achieve the peace of mind for which they bargained. claims. Grande held that the second case could proceed, in part because the staffing company’s settlement agreement did not release claims against the hospital. The agreement did not expressly include the hospital as a releasee, and the more general release of claims against the company’s agents did not apply to the hospital. A dissenting opinion noted that another case reached the opposite conclusion—a staffing agency’s client was the staffing company's agent, and therefore within the scope of the release that the employees had given. Because the California Supreme Court has granted review in Grande, its lasting effect remains uncertain.
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