Garcia v. Seacon Logix, Inc., 190 Cal. Rptr. 3d 400 (Cal. Ct. App. 2015)

Romeo Garcia and other plaintiffs were truck drivers who transported cargo for Seacon Logix. After the Ports of Los Angeles and Long Beach began to implement a clean air program, which prohibited older trucks from accessing the ports, companies such as Seacon purchased new, less polluting trucks to replace the older, higher emission trucks that had been owned and operated by the truck drivers. Although the truck drivers no longer owned the trucks they drove, Seacon continued to treat the drivers as independent contractors (which had been their traditional relationship with Seacon), requiring them to enter into lease agreements for the use of the trucks and deducting lease and insurance payments from their paychecks. In this lawsuit, the truck drivers sought reimbursement for those deductions on the ground that they are employees and not independent contractors. The Labor Commissioner and the trial court agreed and entered judgment in favor of the drivers. The Court of Appeal affirmed, holding that the trial court’s judgment is supported by substantial evidence that Seacon controlled the manner and means of the drivers’ work and that secondary factors such as the right to discharge at will and the provision by Seacon of the instrumentalities, tools and place of work proved the drivers are employees and not independent contractors.