Narrative Opinion Summary
The case involved an appeal by Field Asset Services, Inc. (FAS) against the class certification of 156 independent contractors, the summary judgment favoring the plaintiffs, and an interim award of attorneys' fees exceeding five million dollars. The Ninth Circuit Court reversed the district court's class certification under Federal Rule of Civil Procedure 23(b)(3), citing the predominance of individualized questions over common ones, rendering the class certification improper. The court highlighted the application of the Dynamex standard for overtime claims while Borello governed expense reimbursement claims. The panel found summary judgment inappropriate under the ABC test's parts A and C due to factual disputes but justified under part B, as FAS did not demonstrate that the workers performed services outside its usual business activities. The court vacated the interim attorneys' fees award, citing errors in class certification and summary judgment. Additionally, genuine factual disputes regarding the business-to-business exception under Cal. Labor Code § 2776 led to the conclusion that summary judgment on the class's overtime claims was unwarranted, requiring further proceedings on remand. The outcome remanded all issues back to the district court for consistent proceedings, with costs awarded to FAS.
Legal Issues Addressed
Application of Dynamex and Borello Standardssubscribe to see similar legal issues
Application: The Dynamex standard was applied to Bowerman’s overtime claims, while Borello governed the expense reimbursement claims.
Reasoning: The panel clarified that Dynamex governs Bowerman’s overtime claims, as the expense reimbursement claims presented were not based on California wage orders, but on Cal. Labor Code § 2802.
Business-to-Business Exception under Cal. Labor Code § 2776subscribe to see similar legal issues
Application: The application of this retroactive exception was found to have genuine factual disputes, affecting the summary judgment on overtime claims.
Reasoning: The enactment of Cal. Labor Code § 2776 introduced a retroactive business-to-business exception to the ABC test, allowing Borello’s criteria to govern employee status if twelve specific conditions are met.
Class Certification under Federal Rule of Civil Procedure 23(b)(3)subscribe to see similar legal issues
Application: The court reversed the district court's certification of the class due to the predominance of individualized questions over common questions.
Reasoning: The Ninth Circuit Court of Appeals addressed the case involving Fred Bowerman and Julia Bowerman against Field Asset Services, Inc. The panel issued an order and an amended opinion reversing the district court's certification of a class of 156 individuals who had worked as independent contractors for FAS, stating that the certification was improper due to a predominance of individualized questions over common ones.
Interim Attorneys’ Feessubscribe to see similar legal issues
Application: The interim award of attorneys' fees was vacated due to errors in class certification and summary judgment orders.
Reasoning: The panel vacated the interim award of attorneys’ fees, determining that the orders for class certification and summary judgment were erroneous.
Summary Judgment on Employment Classificationsubscribe to see similar legal issues
Application: The court found that summary judgment was inappropriate for overtime claims under Dynamex due to factual disputes but justified for part B of the ABC test.
Reasoning: The panel determined that summary judgment was inappropriate under parts A and C of the test due to factual disputes over whether vendors were free from FAS’s control and whether they operated an independent business. However, summary judgment was justified under part B, as FAS did not meet the requirement that the workers performed services outside its usual business activities.