Law School Case Brief
Cotter v. Lyft, Inc. - 60 F. Supp. 3d 1067 (N.D. Cal. 2015)
Under California law, if reasonable people could differ on whether a worker is an employee or an independent contractor based on the evidence in the case, the question is not for a court to decide; it must go to the jury. This is true even if no significant dispute exists about the underlying facts, because the act of weighing and applying numerous intertwined factors, based on particular facts, is itself generally the job of the jury. Only when a court concludes that from all the facts only a single inference and one conclusion may be drawn may the court rule on the question as a matter of law, without the need for a jury trial.
Defendant Lyft, Inc., operated a smartphone application through which passengers were matched with nearby drivers who were available to transport people in their personal automobiles. Plaintiffs Patrick Cotter and others were former Lyft drivers. They filed a lawsuit against lift in federal district court contending that Lyft owed them money because it should have paid them as employees rather than independent contractors. According to plaintiffs, Lyft should have reimbursed them for expenses, and that, at least sometimes, Lyft failed to pay them minimum wage. Plaintiffs and Lyft filed cross-motions for summary judgment, with plaintiffs urging the court to declare them "employees" as a matter of law, and Lyft urging the court to declare them "independent contractors" as a matter of law.
Could plaintiffs be declared "employees" of Lyft as a matter of law?
The court denied the parties' motions for summary judgment. The court that under California law, the question of how to classify a worker was typically for a jury. A court could only decide the question as a matter of law if application of the multitude of relevant factors would require any reasonable juror to reach the same conclusion. In the present case, because the numerous factors for deciding whether a worker was an employee or an independent contractor pointed in decidedly different directions, a reasonable jury could go either way. Accordingly, a trial was required.
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