Cotter v. Lyft, Inc.
60 F. Supp. 3d 1059
N.D. Cal.2014Background
- Cotter and Maciel, Lyft drivers, sue in a putative nationwide class under California wage and hour laws.
- Plaintiffs claim California law should apply to all drivers nationwide because Lyft decisions were made in California.
- Court issued an order to show cause and then struck the class allegations, allowing amendments within 21 days.
- Plaintiffs contend California wage and hour provisions could apply to work performed entirely in other states if California has a connection.
- Court concludes California wage and hour laws do not apply to workers who work exclusively outside California.
- Court notes constitutional concerns and the extraterritorial limits of California law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether California wage and hour law applies to workers who perform work exclusively outside California | Cotter/Maciel argue California law can apply due to California connections | Lyft contends laws do not extraterritorially apply to out-of-state work | California wage and hour law does not apply extraterritorially to out-of-state work |
| Whether conflict-of-laws analysis is necessary for nationwide class claims under California law | Plaintiffs argue California law applies if no state has greater interest | Lyft argues only one state's law can apply when work is exclusively outside California | Conflict-of-laws analysis unnecessary; no California statutory action for out-of-state work |
| Whether the California choice-of-law provision in Lyft-driver contracts creates a California wage-and-hour claim | Plaintiffs contend contract grants California-based rights to nonresidents | Lyft argues contract cannot create a nonstatutory California wage claim where none exists | Choice-of-law clause does not create extraterritorial wage claims; inapplicable to out-of-state work |
| Whether the class claims should be maintained or stricken for lack of a California wage-and-hour action | Class claims stricken with leave to amend; 21 days to amend |
Key Cases Cited
- North Alaska Salmon Co. v. Pillsbury, 174 Cal. 1 (Cal. 1916) (extraterritoriality presumption for state statutes)
- Tidewater Marine W., Inc. v. Bradshaw, 14 Cal.4th 557 (Cal. 1996) (employee wage orders generally limited to California residents/work; limited extraterritorial application)
- Sullivan v. Oracle Corp., 51 Cal.4th 1191 (Cal. 2011) (focus on location of work; California law applies to overtime in California, not out-of-state)
- Gravquick A/S v. Trimble Navigation Int’l Ltd., 323 F.3d 1219 (9th Cir. 2003) (choice-of-law provision may govern contract interpretation but not extend wage-law reach)
- Elijahjuan v. Superior Court, 210 Cal.App.4th 15 (Cal. Ct. App. 2012) (statutes conferring worker rights operate independently of contract terms)
- Galen v. Redfin Corp., 227 Cal.App.4th 1525 (Cal. Ct. App. 2014) (courts may treat related conduct differently; some cite to non-California wage claims)