Ruiz v. Affinity Logistics Corp.
667 F.3d 1318
| 9th Cir. | 2012Background
- Affinity hires Ruiz as a driver under Independent Truckman's Agreement and Equipment Lease Agreement labeling him an independent contractor; Georgia law governs disputes per the clause.
- District court granted partial summary judgment on FLSA claims; remaining issues turned on whether Ruiz was an employee or independent contractor.
- Choice-of-law depended on the agreement’s Georgia clause; district court applied Georgia law using a presumption of independent contractor status.
- Bench trial determined a Georgia presumption of independent contractor status remained unrebutted; court entered judgment for Affinity.
- On appeal Ruiz argued California law should govern the employee/independent contractor issue under California choice-of-law framework; the panel vacated and remanded.
- California appellate focus: Properly applying California’s framework would require applying California law to determine employee/contractor status.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether California’s choice-of-law framework applies to determine the employee/contractor status | Ruiz argues California law governs the status determination | Affinity argues Georgia law should apply | California framework applies; remand for California law determination |
| Whether Georgia law’s application contravenes California policy | Ruiz contends Georgia policy conflicts with California employee protections | Affinity maintains Georgia law governs status | Georgia law contravenes California policy; California law governs on remand |
| Whether California has a greater governmental interest in the determination | Ruiz asserts California has greater interest due to performance and contract in California | Affinity contends Georgia interest suffices | California has materially greater interest; California law applies on remand |
Key Cases Cited
- Nedlloyd Lines B.V. v. Superior Court, 3 Cal.4th 459 (Cal. 1992) (California choice-of-law framework requires considering policy and interests beyond relationship)
- ABF Capital Corp. v. Osley, 414 F.3d 1061 (9th Cir. 2005) (substantial relationship is not alone; must assess California policy and interests)
- 1-800-Got Junk? LLC v. Superior Court, 189 Cal.App.4th 500 (Cal. App. 2010) (multifactor interest analysis under California framework)
- S.G. Borello & Sons, Inc. v. Dep’t of Indus. Rel., 48 Cal.3d 341 (Cal. 1989) (multi-factor test for employee vs. independent contractor with remedial purposes)