Hall v. Cultural Care, Inc.

CourtDistrict Court, N.D. California
DecidedJuly 22, 2022
Docket3:21-cv-00926
StatusUnknown

This text of Hall v. Cultural Care, Inc. (Hall v. Cultural Care, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hall v. Cultural Care, Inc., (N.D. Cal. 2022).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 MELISSA HALL, Case No. 3:21-cv-00926-WHO

8 Plaintiff, ORDER ON MOTIONS FOR 9 v. SUMMARY JUDGMENT

10 CULTURAL CARE USA, et al., Re: Dkt. Nos. 57, 62, 68, 71 Defendants. 11

12 13 The plaintiffs in these consolidated putative class actions worked as local childcare 14 coordinators (“LCCs”) who coordinated the work of individuals in the United States on “au pair” 15 visas. Defendant Cultural Care, Inc. (“Cultural Care”), a sponsor for the program, classified the 16 plaintiffs as independent contractors. The plaintiffs filed this suit alleging that they should have 17 been classified as employees under California law. 18 Both parties move for summary judgment on misclassification; the plaintiffs’ motion is 19 granted and Cultural Care’s is denied. The parties’ central disagreement is which legal test for 20 classification—the Borello test or the ABC test—applies. During the class period here, the law 21 was settled that the ABC test, which is better for the plaintiffs, would govern. To resist this, 22 Cultural Care relies on a 2020 statute providing that the Borello test, which is better for Cultural 23 Care, would apply to LCCs—and that it would do so retroactively. To the extent that provision 24 would retroactively diminish wages that the plaintiffs had already earned, it violates the California 25 Constitution’s guarantee of due process. Once the ABC test is applied, it is clear that the plaintiffs 26 should have been classified as employees and are entitled to summary judgment. 27 BACKGROUND 1 statutory mandate to “increase mutual understanding between the people of the United States and 2 the people of other countries by means of educational and cultural exchanges.” 22 C.F.R. § 3 62.1(a). One aspect of that program gives special visas to certain groups of foreign citizens to 4 come to the United States to foster cultural and educational exchanges. See id. et seq. A purpose 5 for which the program exists is to admit what State Department (and the parties here) refer to as au 6 pairs. See id. § 62.31(a). Au pairs “live with an American host family and participate directly in 7 the home life of the host family” to provide “child care services” while attending an American 8 “post-secondary educational institution.” Id. 9 Cultural Care is a “sponsor” for the program. Under regulations, the State Department 10 “designate[s]” sponsors to perform a variety of roles. Id. § 62.31(c). Those roles are discussed in 11 more detail below because they are a key part of the parties’ dispute. At a high level, sponsors 12 coordinate the program for au pairs. See id. (listing requirements). That includes placing au pairs 13 with host families, id. § 62.31(e), holding an orientation according to State Department 14 requirements, id. § 62.31(f), training au pairs in “child development” and “child safety,” id. § 15 62.31(g), “screen[ing]” host families for various requirements, id. § 62.31(h), providing an 16 orientation for host families, id. § 62.31(i), ensuring au pairs are correctly compensated, id. § 17 62.31(j), ensuring au pairs receive proper time off and vacation, id., ensuring au pairs meet their 18 educational requirements, id. § 62.31(k), “monitor[ing]” au pairs, id. § 62.31(l), and fulfilling 19 reporting requirements to the government, id. § 62.31(m). 20 Cultural Care and other sponsors employ or contract with (depending on which party’s 21 argument is correct) a class of individuals that the regulations refer to as “local counselor[s],” id. § 22 62.31(i)(4), or “local organizational representative[s],” id. § 62.31(c)(5). The parties here refer to 23 them as local childcare coordinators (as noted, “LCCs”) and I do the same. Named plaintiffs 24 Melissa Hall, Nicole Ludwig, and Paula Ventura were LCCs for Cultural Care at various points 25 between April 2016 and November 2020. See Plaintiffs’ Consolidated Motion for Summary 26 Judgment (Pl. Mot.”) [Dkt. No. 62] 4 n.2 (collecting citations). Cultural Care classified LCCs as 27 independent contractors. See, e.g., id 6; Opposition to the Pl. Mot. (“Pl. Oppo.”) [Dkt. No. 78] 5 1 These three consolidated cases were filed individually in California state court and 2 removed to this court in February 2021. See, e.g., Dkt. No. 1.1 The plaintiffs allege that Cultural 3 Care misclassified them as independent contractors; they claim that they should have been 4 classified as employees under California law. The cases were eventually consolidated, see Dkt. 5 No. 27, and the plaintiffs filed their operative complaints. See, e.g., Second Amended Complaint 6 (“SAC”) [Dkt. No. 42]. The SAC includes a variety of claims under the California labor law, such 7 as failure to pay wages owed and failure to provide full required breaks, that depend on their 8 misclassification theory, and a derivative claim under the Unfair Competition Law (“UCL”). See 9 generally id. The parties now both move for summary judgment on various issues. 10 LEGAL STANDARD 11 Summary judgment on a claim or defense is appropriate “if the movant shows that there is 12 no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of 13 law.” Fed. R. Civ. P. 56(a). In order to prevail, a party moving for summary judgment must show 14 the absence of a genuine issue of material fact with respect to an essential element of the non- 15 moving party’s claim, or to a defense on which the non-moving party will bear the burden of 16 persuasion at trial. See Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). Once the movant has 17 made this showing, the burden then shifts to the party opposing summary judgment to identify 18 “specific facts showing there is a genuine issue for trial.” Id. The party opposing summary 19 judgment must then present affirmative evidence from which a jury could return a verdict in that 20 party’s favor. Anderson v. Liberty Lobby, 477 U.S. 242, 257 (1986). 21 On summary judgment, the court draws all reasonable factual inferences in favor of the 22 non-movant. Id. at 255. In deciding a motion for summary judgment, “[c]redibility 23 determinations, the weighing of the evidence, and the drawing of legitimate inferences from the 24 facts are jury functions, not those of a judge.” Id. However, conclusory and speculative testimony 25 does not raise genuine issues of fact and is insufficient to defeat summary judgment. See 26 Thornhill Publ’g Co., Inc. v. GTE Corp., 594 F.2d 730, 738 (9th Cir. 1979). 27 1 DISCUSSION 2 Both parties move for summary judgment on the core issue of whether Cultural Care 3 misclassified LCCs as independent contractors instead of employees under California law. See 4 generally Defendant’s Motion for Summary Judgment (“Def. Mot.”) [Dkt. No. 57]; Pl. Mot. And 5 the plaintiffs move for summary judgment on claims and affirmative defenses that are derivative 6 of this determination. See generally Pl. Mot.2 7 I. THE PROPER TEST 8 The parties raise a common issue in California-law misclassification suits: the proper test 9 to determine whether someone is an employee or an independent contractor. There are two 10 possible tests that can apply, the Borello test and the Dynamax or “ABC” test. See Hill v. Walmart 11 Inc., 32 F.4th 811, 819 (9th Cir. 2022).

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Hall v. Cultural Care, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/hall-v-cultural-care-inc-cand-2022.