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Castellanos v. State of California

Castellanos v. State of California

Court of Appeal of California, First Appellate District, Division Four

March 13, 2023 Opinion Filed

Civil No. A163655

Opinion

BROWN, Acting P. J.—In November 2020, the voters approved Proposition 22, the Protect App-Based Drivers and Services Act (Proposition 22). (Bus. & Prof. Code,3 §§ 7448–7467, as added by Prop. 22, approved by the voters at Gen. Elec. (Nov. 3, 2020).) Shortly afterwards, Hector Castellanos, Joseph Delgado, Saori Okawa, Michael Robinson, Service Employees International [*143]  Union California State Council, and Service Employees International Union (SEIU; collectively, plaintiffs) filed a petition for writ of mandate seeking a declaration that Proposition 22 is invalid because it violates the California Constitution.4 The trial court granted the petition, ruling that the proposition (1) is invalid in its entirety because it intrudes on the Legislature's exclusive authority to create workers' compensation laws; (2) is invalid to the extent that it limits the Legislature's authority to enact legislation that would not [**7]  constitute an amendment to Proposition 22, and (3) is invalid in its entirety because it violates the single-subject rule for initiative statutes.

CA(1)(1) Proposition 22's proponents and the state appeal, arguing the trial court was mistaken on all three points. We agree that Proposition 22 does not intrude on the Legislature's workers' compensation authority or violate the single-subject rule, but we conclude that the initiative's definition of what constitutes an amendment violates separation of powers principles. Because the unconstitutional provisions can be severed from the rest of the initiative, we affirm the judgment insofar as it declares those provisions invalid and to the extent the trial court retained jurisdiction to consider an award of attorney fees, and otherwise reverse.

BACKGROUND

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89 Cal. App. 5th 131 *; 2023 Cal. App. LEXIS 183 **; 2023 WL 2473326

HECTOR CASTELLANOS et al., Plaintiffs and Respondents, v. STATE OF CALIFORNIA et al., Defendants and Appellants; PROTECT APP-BASED DRIVERS AND SERVICES et al., Interveners and Appellants.

Prior History:  [**1] Alameda County Superior Court No.RG21088725—Hon. Frank Roesch, Judge

Castellanos v. State, 2021 Cal. Super. LEXIS 7285 (Cal. Super. Ct., Aug. 20, 2021)

Disposition: The judgment is affirmed in part, reversed in part, and remanded.

CORE TERMS

initiative, workers' compensation, voters, drivers, app-based, provisions, initiative power, interveners, independent contractor, invalid, plaintiffs', benefits, purposes, courts, complete system, ballot, single-subject, declares, trial court, separation of powers, legislative power, amend, unlimited, collective bargaining, construing, enact, legislative authority, state government, proponents, bargain

Constitutional Law, State Constitutional Operation, Governments, Legislation, Initiative & Referendum, Interpretation, Case or Controversy, Constitutionality of Legislation, Inferences & Presumptions, Effect & Operation, Amendments, State & Territorial Governments, Legislatures, Workers' Compensation & SSDI, Administrative Proceedings, Coverage, Severability, Labor & Employment Law, Employment Relationships, Independent Contractors, The Judiciary, Constitutionality of Legislation, Advisory Opinions, Ripeness, Courts, Authority to Adjudicate, Separation of Powers