California Supreme Court Watch

#23-128 Castellanos v. State of California, S279622. (A163655; 89 Cal.App.5th 131, mod. 90 Cal.App.5th 84a; Alameda County Superior Court; RG21088725.) Petition for review after the Court of Appeal affirmed in part and reversed in part the judgment in an action for writ of mandate. This case presents the following issue: Is Proposition 22 (the “Protect App-Based Drivers and Services Act”) invalid because it conflicts with article XIV, section 4 of the California Constitution?

Petition for review granted: 6/28/2023

Issues ordered limited: 7/12/2023

Review was granted in this matter on June 28, 2023. The issue to be briefed and argued is limited to the following: Does Business and Professions Code section 7451, which was enacted by Proposition 22 (the “Protect App-Based Drivers and Services Act”), conflict with article XIV, section 4 of the California Constitution and therefore require that Proposition 22, by its own terms, be deemed invalid in its entirety?

Case fully briefed: 2/01/2024

Cause argued (not yet submitted): 5/21/2024

Submitted by order: 6/03/2024

Opinion filed; judgment affirmed in full: 7/25/2024

See the Court of Appeal Opinion.

See the Petition for Review.

See the Oral Argument.

See the California Supreme Court Opinion.  (Castellanos et al. v. State of California et al. (2024) 16 Cal.5th 588.)

“We agree with the Attorney General that [Business and Professions Code] section 7451 does not conflict with [California Constitution] article XIV, section 4 because the latter provision does not preclude the electorate from exercising its initiative power to legislate on matters affecting workers’ compensation. Whether the operation of section 7465 and article II, section 10(c) improperly constrains the Legislature’s article XIV, section 4 authority to enact future legislation is not presented here, and we express no view on that question.

…

We affirm the judgment of the Court of Appeal insofar as it held that Business and Professions Code section 7451 does not conflict with article XIV, section 4 of the California Constitution.”

Justice Liu authored the opinion of the Court, in which Chief Justice Guerrero and Justices Corrigan, Kruger, Groban, Jenkins, and Evans concurred.

In the news: Tan, In Win for Uber and Lyft, California Court Upholds Gig-Worker Proposition, N.Y. Times (July 25, 2024).

In the news: Spoto, et al., California Gig Workers to Remain Contractors, Prop 22 Upheld, Bloomberg Law (July 25, 2024).

In the news: Irwin, California Supreme Court rules Uber, Lyft drivers classified as contractors, The Hill (July 25, 2024).