Castellanos v. State of California centered on the constitutionality of Proposition 22, the “Protect App-Based Drivers and Services Act,” which allowed app-based rideshare and delivery companies to hire drivers as independent contractors if certain conditions were met. 

In its recent decision, the California Supreme Court upheld the constitutionality of Proposition 22, affirming the Court of Appeal decision.

Background

Proposition 22, passed by California voters in November 2020, allowed app-based transportation and delivery companies to classify their drivers as independent contractors rather than employees if certain requirements were met.

The case of Castellanos v. State of California was brought forward by a group of app-based drivers arguing that Proposition 22 violates the California Constitution by limiting the legislature’s ability to enact laws that would grant app-based drivers the right to organize and access to the state’s workers’ compensation program.

In March 2023, the California Court of Appeal upheld the Proposition as mostly constitutional. The Court of Appeal held the Proposition did not intrude on the legislature’s authority. The Court of Appeal did find that the definition of amendment under the Proposition violated the separation of powers principle but could be severed from the rest of the Proposition.

California Supreme Court’s Opinion

The Court’s opinion made a lengthy review of the case law as it pertained to statutes that alleged to convey exclusive powers to the Legislature.

The Court stated that Proposition 22 did not conflict with the Constitution because nothing in the Constitution precluded the electorate from exercising its initiative power to legislate matters affecting workers’ compensation. The Court found that the Legislature was not conferred exclusive power as it pertains to workers’ compensation.

The Court declined to opine on whether the law improperly constrains the Legislature’s authority to enact future legislation.