This Wage and Hour Law Firm Publication by Ford & Harrison LLP discusses a recent decision issued by the California Court of Appeals that California's "death knell" doctrine does not apply to cases in which class certification is denied but representative claims under the state's Private Attorney General Act (PAGA) remain pending. The death knell doctrine allows parties to immediately appeal denials of their class certification motions, but the decision in Munoz v. Chipotle Mexican Grill, Inc. means that the plaintiffs, who pursued wage-related claims against Chipotle, have to wait to appeal the trial court's denial of their class certification motion until after their representative PAGA claims are litigated.