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AB 2288 rewrites PAGA standing from the ground up. The reformed § 2699(c) requires named plaintiffs to have 'personally suffered each of the violations alleged' — language drafted to supersede Huff and eliminate representative claims for violations the plaintiff never experienced. This analysis traces the statutory text, the legislative history confirming the override, and the defense opportunities the new framework creates.

A comprehensive analysis of the cure mechanism enacted by the 2024 PAGA reforms — statutory text, legislative context, procedural requirements, defense strategy framework, and unresolved questions that will shape the next generation of cure litigation.

The LWDA published the first-ever formal PAGA regulations on February 6, 2026. The proposed rules add 33 new sections to the California Code of Regulations covering cure procedures, notice requirements, settlement oversight, and vexatious filer designations. The original comment period closed March 23, 2026; this article includes an October 18 status note.

AB 2288 replaced PAGA's binary penalty structure with a graduated framework of six tiers — from zero (full cure) to $200 (malicious conduct) — calibrated to employer behavior. This analysis maps each tier, the 'all reasonable steps' standard that controls the 15% and 30% caps, and the judicial override discretion that makes every penalty determination negotiable.

The manageability provision gives defense counsel an express basis for targeted trial-evidence and claim-scope limitations. This framework maps the provision onto existing defense strategies and identifies the arguments most likely to gain traction.