United States District Court, N.D. California
For Patrick Cotter, on behalf of himself and all others similarly situated, Plaintiff: John Earl Duke, Shannon Liss-Riordan, Lichten & Liss-Riordan, P.C., Boston, MA; Matthew David Carlson, Carlson Legal Services, San Francisco, CA.
For Alejandra Maciel, on behalf of themselves and all others similarly situated, Plaintiff: Matthew David Carlson, Carlson Legal Services, San Francisco, CA.
For Lyft, Inc., Defendant: Alex Santana, Christopher M. Ahearn, Thomas Michael McInerney, Ogletree Deakins Nash Smoak & Stewart, P.C., San Francisco, CA.
VINCE CHHABRIA, United
States District Judge.
Patrick Cotter and Alejandra Maciel, two former drivers for Lyft, Inc., bring this putative nationwide class action against Lyft under California's wage and hour laws. Specifically, the plaintiffs allege that: (i) California law requires Lyft to treat all drivers throughout the nation as employees rather than independent contractors; and (ii) because Lyft classifies and pays these drivers as independent contractors, it is depriving them of California's minimum wage, along with other
rights that California law confers upon employees.
The Court issued an order to show cause, questioning whether the plaintiffs, who the complaint alleges are California residents who drove for Lyft in California, may bring claims under California's wage and hour laws on behalf of people who drove for Lyft in other states. The Court now strikes the class allegations. If the plaintiffs wish to file an amended complaint that pleads a proper wage and hour class action, they may do so within 21 days.
A. The California Wage And Hour Laws Asserted In The Complaint Do Not Create A Cause Of Action For People Who Perform Work Entirely In Another State.
The plaintiffs argue that California's connection with the claims brought on behalf of the drivers who work in other states is sufficient to justify application of California wage and hour law to those claims. In particular, the plaintiffs allege that Lyft's principal place of business is in California, that its decision to classify drivers as independent contractors was made in California, and that its decision to implement the " administrative fee" that the plaintiffs challenge was made in California. They contend that because of these connections, California wage and hour laws can potentially apply to work performed by drivers exclusively in other states, and the only thing that might bar the application of those laws is if they if conflict with the law of the drivers' home states. Therefore, the plaintiffs argue, they may bring claims on behalf of a nationwide class under California law unless Lyft demonstrates that another state has a greater interest in applying its own law. And the plaintiffs contend that because California's laws are more worker-protective than those of other states, Lyft will be unable to show that the other states have a greater interest in applying their own laws.
There are several problems with this argument. As a preliminary matter, the plaintiffs are wrong that California's wage and hour laws are the most worker-protective. Washington and Oregon, for example, both have higher minimum wages than California. See United States Dep't of Labor, Minimum Wage Laws in the States (Jan. 1, 2014), available at http://www.dol.gov/whd/minwage/america.htm. Therefore, pursuit of claims under California law on behalf of people in those states appears against their interest. Moreover, even if California law were most protective of workers, each state has the right (subject to federal law, of course) to regulate the work performed within its own borders without regard to another state's approach to regulating the employer-employee relationship. But most importantly, by jumping straight to a conflict of laws analysis, the plaintiffs skip an important analytical step. A court conducts a conflict of laws analysis only where the laws of multiple states could conceivably apply to the same claim. Where only one state's law applies, no such analysis is necessary. And as explained below, the ...