16 Cal.5th 588
Cal.2024Background
- Proposition 22 (the Protect App-Based Drivers and Services Act), enacted by California voters in 2020, classifies app-based drivers (e.g., those for Uber, Lyft, DoorDash) as independent contractors, not employees, under certain conditions.
- As independent contractors, these drivers are excluded from coverage under California's workers’ compensation laws, which generally only apply to employees.
- Plaintiffs (Castellanos et al., including SEIU) challenged Prop 22, alleging section 7451 conflicts with article XIV, section 4 of the California Constitution, which grants the Legislature plenary power over the state’s workers’ compensation system.
- Plaintiffs argued that section 7465 of Prop 22, which restricts how the Legislature can amend the law, unlawfully limits the Legislature’s constitutional authority.
- The trial court invalidated Prop 22 as unconstitutional; the Court of Appeal reversed, holding section 7451 does not conflict with the Constitution. The case was appealed to the California Supreme Court.
Issues
| Issue | Plaintiffs’ Argument | Defendants’ Argument | Held |
|---|---|---|---|
| Does Prop 22 section 7451 conflict with art. XIV, sec. 4 of the CA Constitution? | Section 7451 removes a class of workers from the complete workers' comp system, violating the Legislature’s unlimited constitutional power. | Section 7451 does not prevent the Legislature from exercising its authority; the initiative power allows voters to legislate on workers’ comp matters. | No conflict; section 7451 is valid as the initiative power is not precluded by article XIV, sec. 4. |
| Does the "unlimited" clause grant exclusive authority to the Legislature over workers’ comp? | Argues “unlimited” clause excludes the initiative power, reserving exclusive authority to the Legislature. | "Unllimited" is ambiguous; both Legislature and the people (via initiatives) may legislate on workers’ comp. | The constitutional provision is not exclusive; the initiative power is preserved. |
| Does section 7451 improperly restrain future legislative action on workers’ comp? | Section 7465 and article II, sec. 10(c) block the Legislature from restoring workers' comp to app-based drivers w/o voter approval. | The only question before the Court is section 7451, which does not expressly limit legislative power; any future conflict is hypothetical. | Section 7451 itself does not restrain the Legislature; Court does not rule on potential future limitations under section 7465. |
| Must Prop 22 be invalidated in its entirety if section 7451 is unconstitutional? | Argues that section 7451 is not severable; thus, all of Prop 22 should be invalidated if 7451 is unconstitutional. | Not at issue as section 7451 is not unconstitutional. | Not addressed, as section 7451 is upheld. |
Key Cases Cited
- Graczyk v. Workers' Comp. Appeals Bd., 184 Cal.App.3d 997 (statutory nature and exclusiveness of workers’ comp remedies)
- Dynamex Operations West, Inc. v. Superior Court, 4 Cal.5th 903 (ABC test for employee vs. independent contractor distinction)
- McPherson v. Independent Energy Producers Ass’n, 38 Cal.4th 1020 (initiative power is not precluded by constitutional "unlimited" legislative powers language)
- Mathews v. Workmen's Compensation Appeals Board, 6 Cal.3d 719 (purpose of 1918 amendment to confirm constitutionality of workers' comp statutes)
- County of Los Angeles v. State, 43 Cal.3d 46 (potential tension between constitutional mandates and supermajority procedural requirements)
- Western Indem. Co. v. Pillsbury, 170 Cal. 686 (historical background of workers’ comp legislative authority)