A California Court of Appeals held that labor unions lack standing to bring representative actions for wage penalties under California's Private Attorney General Act ("PAGA"). In Amalgamated Transit Union Local 1756 v. Superior Court, two labor unions brought claims under the PAGA and California's Unfair Competition law for unpaid meal and rest breaks on behalf of 150 employees against various transit companies, seeking more than $12 million in unpaid wages and penalties. The court held that while unions may represent employees for purposes of obtaining back pay, unions lack standing to bring claims on behalf of employees for penalties under the PAGA or the Unfair Competition law.