# Castellanos v. State of California

> California Supreme Court · July 25, 2024

URL: https://www.frixlaw.com/law-library/cases/10480895

## Case

- **Court:** California Supreme Court
- **Decided:** July 25, 2024
- **Precedential status:** Published
- **Opinion:** Opinion
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

IN THE SUPREME COURT OF
CALIFORNIA

HECTOR CASTELLANOS et al.,
Plaintiffs and Respondents,
v.
STATE OF CALIFORNIA et al.,
Defendants and Appellants;
PROTECT APP-BASED DRIVERS AND SERVICES et al.,
Interveners and Appellants.

S279622

First Appellate District, Division Four
A163655

Alameda County Superior Court
RG21088725

July 25, 2024

Justice Liu authored the opinion of the Court, in which Chief
Justice Guerrero and Justices Corrigan, Kruger, Groban,
Jenkins, and Evans concurred.
CASTELLANOS v. STATE OF CALIFORNIA
S279622

Opinion of the Court by Liu, J.

This case concerns Business and Professions Code section
7451, which was enacted by the voters through Proposition 22
(Gen. Elec. (Nov. 3, 2020)), the Protect App-Based Drivers and
Services Act (Proposition 22) (Bus. & Prof. Code, §§ 7448–7467;
all undesignated statutory references are to this code). Under
section 7451, a driver for an app-based transportation or
delivery company, such as Uber Technologies, Inc. (Uber), Lyft,
Inc. (Lyft), or DoorDash, Inc., is an independent contractor and
not an employee of the company as long as several conditions
are met. As a result of section 7451, app-based drivers are not
covered by California workers’ compensation laws, which
generally apply to employees and not to independent
contractors.
Plaintiffs Hector Castellanos, Joseph Delgado, Saori
Okawa, Michael Robinson, Service Employees International
Union California State Council, and Service Employees
International Union assert that section 7451 conflicts with
article XIV, section 4 of the California Constitution, which vests
the Legislature “with plenary power, unlimited by any provision
of this Constitution, to create, and enforce a complete system of
workers’ compensation, by appropriate legislation.” (Cal.
Const., art. XIV, § 4; all undesignated article references are to
the California Constitution.) They further contend that because
section 7465 and article II, section 10, subdivision (c) (article II,
section 10(c)) together operate to require voter approval of any

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legislation amending section 7451, those provisions restrict the
Legislature’s “unlimited” power to govern workers’
compensation under the terms of article XIV, section 4.
Interveners Protect App-Based Drivers and Services, Davis
White, and Keith Yandell acknowledge that section 7465 and
article II, section 10(c) would restrict the Legislature’s power to
restore app-based drivers’ eligibility for workers’ compensation,
but they see no inconsistency between this effect of Proposition
22 and article XIV, section 4. The Attorney General contends
that although section 7465 and article II, section 10(c) may
conflict with article XIV, section 4, those provisions are not
before us. According to the Attorney General, the sole provision
at issue in this case, section 7451, does not itself conflict with
article XIV, section 4 because the latter provision does not
assign the Legislature sole authority, to the exclusion of the
initiative power, to govern workers’ compensation.
We agree with the Attorney General that section 7451
does not conflict with article XIV, section 4 because the latter
provision does not preclude the electorate from exercising its
initiative power to legislate on matters affecting workers’
compensation. Whether the operation of section 7465 and
article II, section 10(c) improperly constrains the Legislature’s
article XIV, section 4 authority to enact future legislation is not
presented here, and we express no view on that question.
I.
Article XIV, section 4 provides in relevant part: “The
Legislature is hereby expressly vested with plenary power,
unlimited by any provision of this Constitution, to create, and
enforce a complete system of workers’ compensation, by
appropriate legislation, and in that behalf to create and enforce

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a liability on the part of any or all persons to compensate any or
all of their workers for injury or disability . . . .” A “complete
system of workers’ compensation” includes, among other things,
“adequate provisions for the comfort, health and safety and
general welfare of any and all workers,” “full provision for
securing safety in places of employment,” and “full provision for
adequate insurance coverage against liability to pay or furnish
compensation.” (Ibid.) “[A]ll of which matters are expressly
declared to be the social public policy of this State.” (Ibid.)
“The right to workers’ compensation benefits is ‘wholly
statutory,’ ” “exclusive of all other statutory and common law
remedies, and substitutes a new system of rights and obligations
for the common law rules governing liability of employers for
injuries to their employees.” (Graczyk v. Workers’ Comp.
Appeals Bd. (1986) 184 Cal.App.3d 997, 1002, 1003.) The
workers’ compensation statutes are based on the theory that the
common law remedy for work injuries “involves intolerable
delay and great economic waste, gives inadequate relief for loss
and suffering, operates unequally as between different
individuals in like circumstances, and . . . is inequitable and
unsuited to the conditions of modern industry.” (Western Indem.
Co. v. Pillsbury (1915) 170 Cal. 686, 693 (Western Indemnity).)
In 2019, the Legislature enacted Assembly Bill No. 5
(2019–2020 Reg. Sess.) (Assembly Bill 5) to address “[t]he
misclassification of workers as independent contractors,” which
it identified as “a significant factor in the erosion of the middle
class and the rise in income inequality.” (Stats. 2019, ch. 296,
§ 1, subd. (c).) The Legislature sought to ensure that
misclassified workers “have the basic rights and protections
they deserve under the law, including a minimum wage,
workers’ compensation if they are injured on the job,

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unemployment insurance, paid sick leave, and paid family
leave.” (Stats. 2019, ch. 296, § 1, subd. (e).) To achieve this aim,
Assembly Bill 5 codified the “ABC test” set forth in Dynamex
Operations West, Inc. v. Superior Court (2018) 4 Cal.5th 903.
(Stats. 2019, ch. 296, § 1.) Under that test, a worker is an
independent contractor only if the hiring entity establishes: “(A)
that the worker is free from the control and direction of the hirer
in connection with the performance of the work, both under the
contract for the performance of the work and in fact; (B) that the
worker performs work that is outside the usual course of the
hiring entity’s business; and (C) that the worker is customarily
engaged in an independently established trade, occupation, or
business of the same nature as the work performed for the hiring
entity.” (Dynamex, at pp. 916–917; see Lab. Code, § 2775,
subd. (b)(1).)
Assembly Bill 5 took effect in January 2020. (Stats. 2019,
ch. 296, § 2.) In October 2020, the Court of Appeal in People v.
Uber Technologies, Inc. (2020) 56 Cal.App.5th 266, 273,
prohibited Uber and Lyft from misclassifying their drivers as
independent contractors under Assembly Bill 5. The court said
“we have little doubt the Legislature contemplated that those
who drive for Uber and Lyft would be treated as employees”
under Assembly Bill 5. (Uber Technologies, at p. 297.)
In November 2020, Protect App-Based Drivers and
Services supported Davis White and Keith Yandell in placing
Proposition 22 on the general election ballot. Proposition 22
states that its purposes are to “protect the basic legal right of
Californians to choose to work as independent contractors with
rideshare and delivery network companies,” “protect the
individual right of every app-based rideshare and delivery
driver to have the flexibility to set their own hours for when,

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where, and how they work,” and “require rideshare and delivery
network companies to offer new protections and benefits for app-
based rideshare and delivery drivers, including minimum
compensation levels, insurance to cover on-the-job injuries,
automobile accident insurance, health care subsidies for
qualifying drivers, protection against harassment and
discrimination, and mandatory contractual rights and appeal
processes.” (§ 7450, subds. (a), (b) & (c).) Proposition 22 passed
with the support of 58.6 percent of the voters and enacted
sections 7448 to 7467 of the Business and Professions Code.
Section 7451 is the focus of this appeal. It provides:
“Notwithstanding any other provision of law, including, but not
limited to, the Labor Code, the Unemployment Insurance Code,
and any orders, regulations, or opinions of the Department of
Industrial Relations or any board, division, or commission
within the Department of Industrial Relations, an app-based
driver is an independent contractor and not an employee or
agent with respect to the app-based driver’s relationship with a
network company if the following conditions are met: [¶] (a) The
network company does not unilaterally prescribe specific dates,
times of day, or a minimum number of hours during which the
app-based driver must be logged into the network company’s
online-enabled application or platform. [¶] (b) The network
company does not require the app-based driver to accept any
specific rideshare service or delivery service request as a
condition of maintaining access to the network company’s
online-enabled application or platform. [¶] (c) The network
company does not restrict the app-based driver from performing
rideshare services or delivery services through other network
companies except during engaged time. [¶] (d) The network

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company does not restrict the app-based driver from working in
any other lawful occupation or business.” (§ 7451.)
The statute defines a “ ‘[n]etwork company’ ” as a business
entity that “maintains an online-enabled application or platform
used to facilitate delivery [or transportation] services within the
State of California on an on-demand basis . . . .” (§ 7463,
subds. (l), (f); see id., subd. (p).) Network companies are
required to provide app-based drivers certain benefits and
protections, including “a guaranteed minimum level of
compensation for app-based drivers that cannot be reduced”
(§ 7453, subd. (a)), “a quarterly health care subsidy to qualifying
app-based drivers” (§ 7454, subd. (a)), and “occupational
accident insurance to cover medical expenses and lost income
resulting from injuries suffered while the app-based driver is
online” (§ 7455, subd. (a)).
Section 7465 specifies the procedure for amending
Proposition 22: “After the effective date of this chapter, the
Legislature may amend this chapter by a statute passed in each
house of the Legislature by rollcall vote entered into the journal,
seven-eighths of the membership concurring, provided that the
statute is consistent with, and furthers the purpose of, this
chapter.” (§ 7465, subd. (a).) “Any statute that amends Section
7451 does not further the purposes of this chapter.” (§ 7465,
subd. (c)(2).)
Section 7467 states that “the provisions of this chapter are
severable. If any portion, section, subdivision, paragraph,
clause, sentence, phrase, word, or application of this chapter is
for any reason held to be invalid by a decision of any court of
competent jurisdiction, that decision shall not affect the validity
of the remaining portions of this chapter.” (§ 7467, subd. (a).)

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But “if any portion, section, subdivision, paragraph, clause,
sentence, phrase, word, or application of Section 7451 . . . is for
any reason held to be invalid by a decision of any court of
competent jurisdiction, that decision shall apply to the entirety
of the remaining provisions of this chapter, and no provision of
this chapter shall be deemed valid or given force of law.”
(§ 7467, subd. (b).)
In February 2021, plaintiffs filed a petition for writ of
mandate in Alameda County Superior Court, naming the State
of California and Katie Hagen, Director of the Department of
Industrial Relations, as defendants. By stipulation of the
parties, the trial court granted interveners leave to oppose the
petition as real parties in interest. The petition alleged that
“Proposition 22 conflicts with article XIV, section 4, by
purporting to entirely remove app-based drivers from the
‘complete system of worker’s compensation’ the Legislature has
extended to them and to limit the authority of the Legislature to
extend such worker’s compensation benefits to app-based
drivers in the future.” Plaintiffs further contended that “the
entirety of Proposition 22 must be invalidated” because section
7451 is not severable. Plaintiffs also argued that other
provisions of Proposition 22 not before us in this appeal are
invalid.
The trial court found Proposition 22 “constitutionally
problematic” because under article II, section 10(c), “the
Legislature may not act to amend or repeal an initiative statute
without a subsequent vote of the people.” Although the court
concluded that the people have authority to enact workers’
compensation laws through the initiative power, the court
characterized section 7451 as “an unconstitutional continuing
limitation on the Legislature’s power to exercise its plenary

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power to determine what workers must be covered or not
covered by the worker’s compensation system.” The court
explained, “[I]f the People wish to use their initiative power to
restrict or qualify a ‘plenary’ and ‘unlimited’ power granted to
the Legislature, they must first do so by initiative constitutional
amendment, not by initiative statute.” Given that section 7451
is not severable, the court held Proposition 22 invalid in its
entirety. The court also held Proposition 22 unconstitutional on
other grounds not at issue here.
The Attorney General and interveners appealed, and a
divided Court of Appeal reversed. The court first concluded that
under article XIV, section 4, the voters and the Legislature
“jointly and severally have authority to create a workers’
compensation system.” (Castellanos v. State (2023) 89
Cal.App.5th 131, 150 (Castellanos).) Relying on Independent
Energy Producers Association v. McPherson (2006) 38 Cal.4th
1020 (McPherson), the court reasoned that article XIV, section 4
does not “require every worker to be covered by workers’
compensation.” (Castellanos, at p. 155.) Observing that “courts
must liberally construe the initiative power and resolve doubts
in favor of the use of the initiative wherever reasonable,” the
Court of Appeal held that Proposition 22 does not conflict with
article XIV, section 4. (Castellanos, at p. 150; see id. at p. 157.)
The court affirmed the trial court’s judgment insofar as it
invalidated severable provisions of Proposition 22 — section
7465, subdivisions (c)(3) and (c)(4) — which are not before us in
the present matter. (Castellanos, at pp. 163–177.)
Justice Streeter disagreed with the Court of Appeal’s
conclusion that Proposition 22 does not conflict with article XIV,
section 4. He explained that Proposition 22 “constitutes a sub
rosa attempt to amend the Constitution in the guise of statutory

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change” and “presents a direct conflict between the voter
electors’ power to adopt initiative statutes and the Legislature’s
power under article XIV, section 4.” (Castellanos, supra, 89
Cal.App.5th at p. 178 (conc. & dis. opn. of Streeter, J.).) “[O]n
this record,” he concluded, “we must resolve that conflict in favor
of the Legislature.” (Ibid.)
Plaintiffs petitioned for our review. We granted the
petition and later limited the issue to be argued and briefed as
follows: “Does Business and Professions Code section 7451,
which was enacted by Proposition 22 (the ‘Protect App-Based
Drivers and Services Act’), conflict with article XIV, section 4 of
the California Constitution and therefore require that
Proposition 22, by its own terms, be deemed invalid in its
entirety?”
II.
In addressing this question, we begin by examining
whether the Legislature’s plenary power under article XIV,
section 4 to legislate on workers’ compensation is exclusive, or
whether the people through the initiative power may also
legislate on matters affecting workers’ compensation by
enacting section 7451.
A.
Plaintiffs assert that the phrase “unlimited by any
provision of this Constitution” (the “unlimited” clause) in article
XIV, section 4 prohibits the initiative statute here. According to
plaintiffs, if “an initiative statute can remove entire classes of
workers from the complete workers’ compensation system
established by the Legislature . . . then the Legislature’s plenary
power is not ‘unlimited.’ ” They ask us to invalidate section 7451
on that basis.

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Our analysis is guided by McPherson, supra, 38 Cal.4th
1020, where we examined the only other provision of the
California Constitution that expressly references the
Legislature’s plenary power, unlimited by any other
constitutional provision, to take a specified action. That
provision is article XII, section 5, which states: “The Legislature
has plenary power, unlimited by the other provisions of this
constitution but consistent with this article, to confer additional
authority and jurisdiction upon the [Public Utilities
Commission] . . . .” We held that article XII, section 5 does not
“preclude[] the use of the initiative process to enact statutes
conferring additional authority upon the [commission].”
(McPherson, at p. 1025.) In other words, the Legislature’s power
under article XII, section 5 is not exclusive of the people’s
initiative power, notwithstanding the “unlimited” clause.
As McPherson observed, the initiative power is recognized
in article IV, section 1 of the California Constitution, which
states: “The legislative power of this State is vested in the
California Legislature which consists of the Senate and
Assembly, but the people reserve to themselves the powers of
initiative and referendum.” We summarized the history of this
provision as follows: “ ‘The amendment of the California
Constitution in 1911 to provide for the initiative and
referendum signifies one of the outstanding achievements of the
progressive movement of the early 1900’s. Drafted in light of
the theory that all power of government ultimately resides in
the people, the amendment speaks of the initiative and
referendum, not as a right granted the people, but as a power
reserved by them. Declaring it “the duty of the courts to
jealously guard the right of the people” [citation], the courts
have described the initiative and referendum as articulating

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“one of the most precious rights of our democratic process”
[citation]. “[I]t has long been our judicial policy to apply a liberal
construction to this power whenever it is challenged in order
that the right be not improperly annulled. If doubts can
reasonably be resolved in favor of the use of this reserve power,
courts will preserve it.” ’ ” (McPherson, supra, 38 Cal.4th at
p. 1032, quoting Associated Home Builders of the Greater
Eastbay, Inc. v. City of Livermore (1976) 18 Cal.3d 582, 591
(Associated Home Builders).)
Mindful of these principles, this court in McPherson
rejected the view that article XII, section 5 conferred exclusive
power on the Legislature to expand the Public Utilities
Commission’s (PUC) authority or jurisdiction. (McPherson,
supra, 38 Cal.4th at p. 1032.) Proponents of the initiative
statute there argued that the phrase “ ‘unlimited by the other
provisions of this constitution’ ” in article XII, section 5 could not
be read literally because doing so “logically would signify that a
statute passed by the Legislature pursuant to article XII, section
5 would not be subject to any provision of the California
Constitution, including, for example, the provision authorizing
the Governor to veto a bill approved by the Legislature. (Cal.
Const., art. IV, § 10.)” (McPherson, at p. 1036.) We agreed that
the “unlimited” clause was “not unambiguous” and could not
“reasonably be interpreted only as having the effect of
precluding the people’s exercise of their reserved initiative
power.” (Ibid.) We then consulted the background of article XII,
section 5 and observed that it was approved at the same 1911
election where voters also approved article IV, section 1
establishing the initiative power. (McPherson, at pp. 1040–
1041.) Given this timing, we found it “most improbable” that
the voters intended, “without any direct or explicit statement to

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this effect, to limit the use of the initiative power” through
article XII, section 5. (McPherson, at p. 1042.)
Relying on McPherson, the Court of Appeal reasoned that
“article XIV, section 4’s ‘unlimited’ clause cannot mean that
workers’ compensation laws are exempt from every other aspect
of the Constitution” and that “it is ambiguous as to which
aspects of the Constitution continue to apply and which do not.”
(Castellanos, supra, 89 Cal.App.5th at p. 150.) Although
Proposition 22 differs in some respects from the initiative
statute at issue in McPherson, we agree with the Court of
Appeal that McPherson is instructive when interpreting the
“nearly identical” “unlimited” clause of article XIV, section 4.
(Castellanos, at p. 150.)
Plaintiffs attempt to distinguish article XIV, section 4’s
“unlimited” clause from the provision at issue in McPherson on
several grounds. First, plaintiffs point out that unlike article
XII, section 5, which was enacted the same year as the initiative
power, the “unlimited” clause was added to article XIV, section
4 in 1918, seven years after the initiative power was added to
the Constitution in 1911. In light of this chronology, plaintiffs
contend the “unlimited” clause of article XIV, section 4
“necessarily encompassed” the existing initiative power. But
this timing does not resolve article XIV, section 4’s ambiguity
because it provides no basis to single out the initiative power
from other constitutional checks on the Legislature’s power such
as the Governor’s veto power. In any event, we agree with the
Court of Appeal that it seems “ ‘most improbable’ that the voters
in 1918 — seven years after they ‘approved a far-reaching
measure incorporating a broad initiative power as part of the
California Constitution’ — would have intended, ‘without any
direct or explicit statement to this effect, to limit the use of the

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initiative power by virtue of the language’ in article XIV, section
4.” (Castellanos, supra, 89 Cal.App.5th at pp. 151–152, quoting
McPherson, supra, 38 Cal.4th at p. 1042.)
Plaintiffs respond that “[e]ven if the 1918 voters did not
have the initiative power in mind,” the “broad and
comprehensive” language of the “unlimited” clause supports
their view that the clause limits the initiative power. But even
plaintiffs do not endorse a literal reading of the “unlimited”
clause such that the Legislature would be entirely free of
constitutional checks or constraints in the area of workers’
compensation. The clause requires interpretation, and without
a specific indication that the 1918 voters who enacted the clause
meant to limit the initiative power, it is “ ‘our judicial policy to
apply a liberal construction to this power wherever it is
challenged in order that the right be not improperly annulled.’ ”
(Associated Home Builders, supra, 18 Cal.3d at p. 591.)
Next, plaintiffs assert that the “unlimited” clause here is
not ambiguous because article XIV, section 4 directs the
Legislature to enact “appropriate legislation” to administer the
workers’ compensation system. They contend that “the
potential ambiguity about the veto power in McPherson arose
only because the constitutional provision at issue there did not
specify how the Legislature could exercise its ‘unlimited’
authority.” Because “[l]egislation is adopted only when a bill is
‘bicamerally enacted and presented to the head of the executive
branch for approval or veto,’ ” plaintiffs argue, the phrase
“appropriate legislation” makes clear that article XIV, section
4’s “unlimited” clause applies only to the initiative power and
not to other constitutional checks on the legislative power.

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Like the Court of Appeal, we believe the phrase “by
appropriate legislation” in article XIV, section 4 “does not
change the analysis.” (Castellanos, supra, 89 Cal.App.5th at
p. 153.) It seems unlikely that the term “appropriate” was
intended to mean that a bill has been bicamerally enacted and
presented to the Governor. “Without following those
procedures, no bill the Legislature passes is binding on anyone.
It is not law at all . . . .” (Id. at p. 193 (conc. & dis. opn. of
Streeter, J.).) Thus, if the authors of article XIV, section 4 had
intended to specify that workers’ compensation statutes must
comply with constitutional checks on legislative power, they
could have simply used the word “legislation,” and the
additional word “appropriate” would be surplusage. Moreover,
plaintiffs’ definition of “appropriate legislation” as legislation
that has been bicamerally enacted and presented to the
Governor does not account for legislation that amends an
initiative statute and must be approved by the voters under
article II, section 10(c). In other words, under our state
Constitution, just as “legislation” ordinarily means a bill that
has been presented to the Governor, “legislation” amending an
initiative statute is a bill that has been approved by the voters
unless the initiative provides otherwise. Plaintiffs’ definition
still requires us to “choos[e] which constitutional provisions
would apply and which would not. It is not clear why the veto
power and the initiative power would fall on different sides of
that line.” (Castellanos, at p. 153.)
In sum, guided by McPherson’s reasoning, we conclude
that the “unlimited” clause is ambiguous and that there is no
textual or historical basis to construe it to apply solely to the
initiative power.

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B.
To discern the meaning of the “unlimited” clause, the
Court of Appeal consulted the ballot materials from the 1918
election at which an amendment to former article XX, section 21
added the “unlimited” clause and enacted what is now article
XIV, section 4. In those materials, the Court of Appeal found no
evidence that the “voters intended to free the Legislature [from
the initiative power] when enacting workers’ compensation
laws.” (Castellanos, supra, 89 Cal.App.5th at p. 151.) The court
agreed with our determination in Mathews v. Workmen’s
Compensation Appeals Board (1972) 6 Cal.3d 719, 734–735
(Mathews) that the 1918 amendment served “ ‘the sole purpose
of removing all doubts as to the constitutionality of the then
existing workmen’s compensation statutes.’ ” (Castellanos, at
p. 151; see Mathews, at p. 732, fn. 9.)
A review of the historical background of the 1918
amendment confirms our conclusion in Mathews. In 1911, the
Roseberry Act (Stats. 1911, ch. 399, § 1, p. 796) established a
voluntary system of workers’ compensation. (Mathews, supra,
6 Cal.3d at p. 729.) One month later, the voters approved article
XX, section 21 (now article XIV, § 4), which provided in relevant
part, “ ‘The Legislature may by appropriate legislation create
and enforce a liability on the part of all employers to compensate
their employees for any injury incurred by the said employees in
the course of their employment irrespective of the fault of either
party.’ ” (Mathews, at p. 730, italics omitted, quoting former art.
XX, § 21.) “Because few employers had chosen coverage under
the voluntary plan established by the Roseberry Act, in 1913 the
Legislature exercised the power conferred upon it by section 21
of article XX and enacted a compulsory scheme of workmen’s
compensation” through what was popularly known as the

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Boynton Act (Stats. 1913, ch. 176, § 1, p. 279). (Mathews, at
p. 730.) The Boynton Act “substitute[d] a new system of rights
and obligations for the common-law rules governing the liability
of employers for injuries to their workmen. . . . In place of the
old action, in which the employer was liable only if he, or some
one representing him, had been guilty of negligence or
misconduct, the new law impose[d] upon the employer a liability
for any accidental injuries to his employees arising out of the
employment . . . .” (Western Indemnity, supra, 170 Cal. at
p. 692.)
Between 1913 and 1918, the Boynton Act was challenged
on multiple constitutional grounds. (See, e.g., Western
Indemnity, supra, 170 Cal. 686; Western Metal Supply Co. v.
Pillsbury (1916) 172 Cal. 407.) In Western Indemnity, we
characterized the Boynton Act as “radical” but held that it did
not violate the California Constitution or the Fourteenth
Amendment to the United States Constitution. (Western
Indemnity, at p. 692, see id. at p. 701.) Justice Henshaw
disagreed, describing the Boynton Act as “obnoxious to the
constitutional provisions guaranteeing equal protection, and
forbidding confiscation,” and predicting that the United States
Supreme Court would grant review of our decision. (Western
Indemnity, at p. 716 (dis. opn. of Henshaw, J.); see id. at p. 721
(dis. opn. of Henshaw, J.).) Justice Shaw agreed with Justice
Henshaw that, under some circumstances, application of the
Boynton Act “would be a taking for a public purpose without
lawful excuse or right and without compensation.” (Western
Indemnity, at p. 735 (conc. opn. dubitante of Shaw, J., on rehg.
den.).) Together, Justice Henshaw and Justice Shaw “cast doubt
on whether former article XX, section 21, provided adequate
support for the Boynton Act as a matter of state law.”

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CASTELLANOS v. STATE OF CALIFORNIA
Opinion of the Court by Liu, J.

(Castellanos, supra, 89 Cal.App.5th at p. 184 (conc. & dis. opn.
of Streeter, J.).)
In 1918, the electorate was presented with an amendment
to article XX, section 21 to address those doubts. The ballot
materials explained that “ ‘[t]he proposed amendment [wa]s
designed to express full authority for legislation; to sanction,
establish and protect the full plan in all essentials where the
courts ha[d] not already passed upon it.’ ” (Mathews, supra, 6
Cal.3d at p. 733, fn. 11, italics omitted.) The ballot materials
also called the amendment “ ‘a necessary amplification and
definition of the constitutional authority vested in the
legislature by the amendment to the Constitution adopted
October 10, 1911, to enable the enactment of a complete plan of
workmen’s compensation . . . .’ ” (Ibid.) The materials further
stated, “Our workmen’s compensation act . . . should be put
upon a firm constitutional basis, beyond the possibility of being
attacked on technical grounds or by reason of any questioned
want of constitutional authority.” (Ballot Pamp., General Elec.
(Nov. 5, 1918) argument in favor of Senate Constitutional
Amendment No. 30, p. 56.) As Mathews explained, this history
demonstrates the voters’ intent to confirm “the constitutionality
of the then existing workmen’s compensation statutes.”
(Mathews, at pp. 734–735.)
In light of this purpose, Mathews rejected a claim that the
1918 amendment invalidated one of the “basic features” of
existing workers’ compensation laws (Mathews, supra, 6 Cal.3d
at p. 735) — “conditioning the right to compensation upon the
absence of wilful misconduct or other intentional wrongdoing”
(id. at pp. 724–725). According to Justice Streeter, Mathews’s
preservation of this “basic feature” of the workers’ compensation
system suggests that “there is a minimum constitutional

17
CASTELLANOS v. STATE OF CALIFORNIA
Opinion of the Court by Liu, J.

baseline to our workers’ compensation system no statute can go
below” and that Proposition 22 falls below that baseline.
(Castellanos, supra, 89 Cal.App.5th at p. 181 (conc. & dis. opn.
of Streeter, J.).) But this misconstrues Mathews. As the Court
of Appeal explained, “[t]he point of Mathews was only that
article XIV, section 4 was intended to authorize the workers’
compensation system that already existed — not that those
features became sacrosanct and untouchable by either the
Legislature or the electorate.” (Castellanos, at p. 151, fn. 8.)
Like Justice Streeter, plaintiffs assert that the 1918
workers’ compensation system “contained the basic elements
necessary to protect workers and their families” and that
Proposition 22 “lacks those basic elements,” thereby
“frustrat[ing] the social public policy” declared by article XIV,
section 4. But we agree with interveners that “the ‘social public
policy’ language [of article XIV, section 4] does not impose a
substantive requirement that the workers’ compensation
system cover any particular group of workers.” Article XIV,
section 4’s declaration that a complete system of workers’
compensation is the “social public policy of the State” does not
alter the extent of what we held in Mathews.
In sum, the history of the 1918 amendment that codified,
in all material respects, the present version of article XIV,
section 4 demonstrates that the amendment was a response to
constitutional challenges to the existing workers’ compensation
system. It does not show that the amendment was meant to
limit the initiative power in any respect.
C.
Plaintiffs further contend that McPherson is inapposite
because of an express limitation in that decision. As noted,

18
CASTELLANOS v. STATE OF CALIFORNIA
Opinion of the Court by Liu, J.

McPherson held that the Legislature’s article XII, section 5
power does not invalidate an initiative statute conferring
additional authority upon the PUC. (McPherson, supra, 38
Cal.4th at p. 1025.) But we said we “ha[d] no occasion” “to
consider whether an initiative measure relating to the PUC may
be challenged on the ground that it improperly limits the PUC’s
authority or improperly conflicts with the Legislature’s exercise
of its authority to expand the PUC’s jurisdiction or authority.”
(Id. at p. 1044, fn. 9.) Plaintiffs assert that this case presents a
situation not addressed by McPherson because “the Legislature
exercised its authority when it enacted [Assembly Bill 5], and
section 7451 conflicts with that exercise of authority.” They also
argue that section 7451 “restrains the Legislature from
exercising its plenary power to provide a complete system of
workers’ compensation.”
We agree that section 7451 contradicts Assembly Bill 5’s
classification of app-based drivers as employees and that
McPherson did not address such a conflict. But in light of our
conclusion that the article XIV, section 4 power is not exclusive,
it would unduly restrict the initiative power to give the
Legislature what would essentially be a first-mover advantage,
precluding the electorate from undoing any action the
Legislature takes pursuant to article XIV, section 4. The power
of initiative includes “the power to abrogate existing [laws].”
(California Redevelopment Assn. v. Matosantos (2011) 53
Cal.4th 231, 255.) Accordingly, the people may alter existing
workers’ compensation policy without running afoul of article
XIV, section 4. We express no view on the outer bounds of that
authority or whether article XIV, section 4 might place limits on
it.

19
CASTELLANOS v. STATE OF CALIFORNIA
Opinion of the Court by Liu, J.

As for plaintiffs’ further concern that section 7451
improperly limits the Legislature’s ability to enact future
workers’ compensation laws, we agree with the Attorney
General that section 7451 does not, by its terms, limit the
Legislature’s power to enact workers’ compensation laws.
Section 7451 operates to classify app-based drivers as
independent contractors instead of employees when certain
criteria are met. Against the backdrop of existing law, this
classification renders app-based drivers ineligible for workers’
compensation because eligibility generally depends on the
existence of an employment relationship. (Lab. Code, § 3600,
subd. (a).) But section 7451 itself says nothing about workers’
compensation, and the Legislature has made a number of
exceptions to the general eligibility rule in order to extend
workers’ compensation to nonemployees. (See, e.g., Lab. Code,
§§ 3360 [providing conditions under which “[w]orkmen
associating themselves under a partnership agreement, the
principal purpose of which is the performance of the labor on a
particular piece of work,” may be treated as employees for
purposes of workers’ compensation], 3363.6, subd. (a) [providing
similar conditions for “a person who performs voluntary service
without pay for a private, nonprofit organization”], 3364 [setting
forth similar conditions for “volunteer, unsalaried member[s] of
a sheriff’s reserve”].) In making these exceptions, the
Legislature has asserted that it is empowered by article XIV,
section 4. (See Lab. Code, § 3201 [“This division and Division 5
(commencing with Section 6300) . . . are intended to make
effective and apply to a complete system of workers’
compensation the provisions of Section 4 of Article XIV of the
California Constitution.”].)

20
CASTELLANOS v. STATE OF CALIFORNIA
Opinion of the Court by Liu, J.

Plaintiffs acknowledge that “[a]n initiative statute that
did not prevent the Legislature from providing app-based
drivers with a complete system of workers’ compensation could
be harmonized with article XIV.” But they argue that such
action by the Legislature would be stymied by section 7465’s
directives that the Legislature may only amend the initiative by
passing a statute (with a seven-eighths majority vote) that “is
consistent with, and furthers the purpose of, this chapter,” and
that “[a]ny statute that amends Section 7451 does not further
purposes of this chapter.” (§ 7465, subds. (a), (c)(2).) As
plaintiffs put it, “future legislation providing workers’
compensation benefits to app-based drivers . . . would constitute
an impermissible amendment of section 7451.” What this
means, according to plaintiffs, is that any act by the Legislature
to restore workers’ compensation eligibility to app-based drivers
would require voter approval because article II, section 10(c)
prohibits the Legislature from amending an initiative statute
without voter approval unless the initiative provides otherwise.
The Attorney General responds that “[i]t would be
premature to address any questions about the Legislature’s
power to enact future legislation that defines app-based drivers
as workers entitled to workers’ compensation” because we
cannot “predict what shape such legislation might take and
what the relevant constitutional analysis would be in assessing
its validity.” We agree. Without any specific legislation before
us, we have no occasion to decide whether a statute providing
app-based drivers workers’ compensation would necessarily
constitute a statute that “amends Section 7451” (§ 7465,
subd. (c)(2)) and triggers the voter approval requirement of
article II, section 10(c). We leave open whether a future statute
that changes the consequences of section 7451 in a discrete area

21
CASTELLANOS v. STATE OF CALIFORNIA
Opinion of the Court by Liu, J.

would properly be characterized as an amendment of section
7451. (Cf., e.g., People v. Rojas (2023) 15 Cal.5th 561, 568;
People v. Kelly (2010) 47 Cal.4th 1008, 1025–1026; People v.
Cooper (2002) 27 Cal.4th 38, 44.)
Under section 7465, the Legislature may amend
provisions of Proposition 22 other than section 7451 as long as
such an amendment “is consistent with, and furthers the
purpose of, this chapter” and obtains a seven-eighths majority
vote in each house of the Legislature. (§ 7465, subd. (a).)
Plaintiffs and the Attorney General contend that section 7465’s
supermajority requirement may conflict with article XIV,
section 4 under our reasoning in County of Los Angeles v. State
(1987) 43 Cal.3d 46 (County of Los Angeles). In County of Los
Angeles, we addressed a potential conflict between article XIV,
section 4 and article XIII B, section 6. Under the latter
provision, “[w]henever the Legislature or any state agency
mandates a new program or higher level of service on any local
government,” the state must reimburse the local government for
costs incurred as a result of the mandate. (Art. XIII B, § 6,
subd. (a).) The question was whether legislation that increased
workers’ compensation benefits for local government employees
was subject to article XIII B, section 6. If so, then the legislation
would have been subject to a supermajority vote under article
IV, section 12. (See County of Los Angeles, at p. 57; art. IV, § 12,
subd. (d) [“Appropriations from the General Fund of the State
. . . are void unless passed in each house by rollcall vote entered
in the journal, two-thirds of the membership concurring.”].)
We explained that “[o]ur concern over potential conflict
arises because article XIV, section 4, gives the Legislature
‘plenary power, unlimited by any provision of this Constitution’
over workers’ compensation.” (County of Los Angeles, supra, 43

22
CASTELLANOS v. STATE OF CALIFORNIA
Opinion of the Court by Liu, J.

Cal.3d at pp. 58–59, fn. omitted.) “A constitutional requirement
that [workers’ compensation] legislation either exclude
employees of local governmental agencies or be adopted by a
supermajority vote” would “curtail the power of a majority to
enact substantive changes by any procedural means.” (Id. at
p. 60.) Because such an interpretation of article XIII B,
section 6 “would have an indirect, but substantial impact on the
ability of the Legislature to make future changes in the existing
workers’ compensation scheme,” we construed article XIII B,
section 6 to avoid that result. (County of Los Angeles, at p. 59.)
Plaintiffs observe that section 7465, unlike article XIII B,
section 6, is part of an initiative statute that is “subordinate to
the Constitution.” They argue that any “limitation on the
Legislature’s power to increase workers’ compensation
benefits,” including section 7465, “would conflict with article
XIV.” And the Attorney General acknowledges that the seven-
eighths majority requirement of section 7465 “may be
constitutionally problematic” in light of County of Los Angeles.
But interveners said during oral argument that County of Los
Angeles is “readily distinguishable,” in part because it did not
actually resolve any conflict between constitutional provisions
since the two provisions at issue could be harmonized.
We have no need in this case to decide the applicability of
our reasoning in County of Los Angeles to Proposition 22 or to
determine the extent to which article XIV, section 4 may limit
the initiative power. We reserve these issues until we are
presented with an actual challenge to an act of the Legislature
providing workers’ compensation to app-based drivers. To
resolve the question presented, it suffices to conclude that
section 7451 does not itself restrict the Legislature’s authority

23
CASTELLANOS v. STATE OF CALIFORNIA
Opinion of the Court by Liu, J.

to enact workers’ compensation legislation or otherwise conflict
with article XIV, section 4.
Plaintiffs assert in their reply and answer to amicus
curiae briefs that the Legislature has already extended workers’
compensation benefits to app-based drivers through Assembly
Bill No. 1766 (2023–2024 Reg. Sess.) (Assembly Bill 1766),
which was enacted after Proposition 22. (Stats. 2023, ch. 133.)
They point to a provision of Assembly Bill 1766 that
prospectively revised the definition of “employee” in Labor Code
section 3351, subdivision (i) to include “any individual who is an
employee pursuant to section 2775.” They say that by
“updat[ing] an obsolete cross-reference” in this provision, the
Legislature “reaffirm[ed] that ‘any individual who is an
employee pursuant to [Labor Code] Section 2775’ (which codifies
the ABC test) is covered by the workers’ compensation system.
(Stats. 2023, ch. 133, § 1 (Assem. Bill No. 1766), effective Jan. 1,
2024.)” But plaintiffs do not cite any authority for their claim
that this updated cross-reference effectively recodifies the ABC
test for app-based drivers, nor do they demonstrate that their
theory has ever been tested in litigation. At this juncture, it is
not clear that “there is already a direct and irreconcilable
conflict between section 7451 and a statute adopted by the
Legislature after Proposition 22 was enacted,” as plaintiffs
contend. In any event, that question is not before us, and we
express no view on it.

24
CASTELLANOS v. STATE OF CALIFORNIA
Opinion of the Court by Liu, J.

CONCLUSION
We affirm the judgment of the Court of Appeal insofar as
it held that Business and Professions Code section 7451 does not
conflict with article XIV, section 4 of the California Constitution.

LIU, J.
We Concur:
GUERRERO, C. J.
CORRIGAN, J.
KRUGER, J.
GROBAN, J.
JENKINS, J.
EVANS, J.

25
See next page for addresses and telephone numbers for counsel who
argued in Supreme Court.

Name of Opinion Castellanos v. State of California
__________________________________________________________

Procedural Posture (see XX below)
Original Appeal
Original Proceeding
Review Granted (published) XX 89 Cal.App.5th 131
Review Granted (unpublished)
Rehearing Granted
__________________________________________________________

Opinion No. S279622
Date Filed: July 25, 2024
__________________________________________________________

Court: Superior
County: Alameda
Judge: Frank Roesch
__________________________________________________________

Counsel:

Rob Bonta, Attorney General, Michael J. Mongan, State Solicitor
General, Thomas S. Patterson, Assistant Attorney General, Samuel T.
Harbourt, Deputy State Solicitor General, Mark R. Beckington, Jose A.
Zelidon-Zepeda and Lara Haddad, Deputy Attorneys General, and
Cara M. Newlon, Associate Deputy State Solicitor General, for
Defendants and Appellants.

DLA Piper, Stanley J. Panikowski and Justin R. Sarno for former
Attorney General Daniel E. Lungren as Amicus Curiae on behalf of
Defendants and Appellants.

DLA Piper and Stanley J. Panikowski for former California
Assemblyman William R. Berryhill as Amicus Curiae on behalf of
Defendants and Appellants.

Eimer Stahl and Robert E. Dunn for Crum & Forster Holding Co. as
Amicus Curiae on behalf of Defendants and Appellants.
California Constitution Center, University of California, Berkeley,
David A. Carrillo; Benbrook Law Group and Stephen M. Duvernay for
California Constitution Scholars as Amici Curiae on behalf of
Defendants and Appellants.

Holland & Knight, Stacey Wang, Amit Agarwal and Keiana Wilkerson
for former State Senators Robert Timothy Leslie and James Stephen
Peace as Amici Curiae on behalf of Defendants and Appellants.

O’Melveny & Myers, Jeffery L. Fisher; Nielsen Merksamer Parrinello
Gross & Leoni, Arthur G. Scotland, Sean P. Welch, Kurt R. Oneto and
David J. Lazarus for Interveners and Appellants.

Eimer Stahl, Robert E. Dunn and Collin J. Vierra for Citizens in
Charge as Amicus Curiae on behalf of Defendants and Appellants and
Interveners and Appellants.

Allen Matkins Leck Gamble Mallory & Natsis, Marshall C. Wallace,
Alexander J. Doherty and Kimberly F. Macey for Citizens in Charge
and The Initiative and Referendum Institute at the University of
Southern California as Amici Curiae on behalf of Defendants and
Appellants and Interveners and Appellants.

Davis Wright Tremaine, Rochelle L. Wilcox and Alexa A. Graumlich
for California Chamber of Commerce as Amicus Curiae on behalf of
Defendants and Appellants and Interveners and Appellants.

Davis Wright Tremaine, Adam S. Sieff, Annie Zhang and David M.
Gossett for Chamber of Progress, NetChoice, Asian Industry B2B, the
Silicon Valley Leadership Group and sf.citi as Amici Curiae on behalf
of Defendants and Appellants and Interveners and Appellants.

Holtzman Vogel Baran Torchinsky Josefiak, Alex Vogel, Edward M.
Wenger and Andrew Pardue for California Policy Center as Amicus
Curiae on behalf of Defendants and Appellants and Interveners and
Appellants.

Willenken, Kenneth M. Trujillo-Jamison and Michelle K. Millard for
California Asian Pacific Chamber of Commerce, NAACP California
Hawaii State Conference, California Hispanic Chambers of Commerce,
Los Angeles Metropolitan Churches, National Action Network Los
Angeles, National Action Network Sacramento Chapter Inc., National
Asian American Coalition and National Diversity Coalition as Amici
Curiae on behalf of Defendants and Appellants and Interveners and
Appellants.

Jenner & Block, Laurie J. Edelstein and Adam G. Unikowsky for
Chamber of Commerce of the United States of America as Amicus
Curiae on behalf of Defendants and Appellants and Interveners and
Appellants.

Baker Botts and Michael W. Ward for Arnold Schwarzenegger as
Amicus Curiae on behalf of Defendants and Appellants and
Interveners and Appellants.

King & Spalding, Albert Giang, Jeffery Hammer, Anne M. Voigts and
Ramon A. Miyar for Marketplace Industry Association, Inc., as Amicus
Curiae on behalf of Defendants and Appellants and Interveners and
Appellants.

Buchalter, Steven G. Churchwell, Berit Elam and Brandon Q. Tran for
Daniel Schnur, T. Anthony Quinn and Robert M. Stern as Amici
Curiae on behalf of Defendants and Appellants and Interveners and
Appellants.

Weintraub Tobin Chediak Coleman Grodin and Brendan J. Begley for
Independent Drivers Alliance of California, Kelly Rickert, Ali Mazhin
and Stephanie Whitfield as Amici Curiae on behalf of Defendants and
Appellants and Interveners and Appellants.

Wilmer Cutler Pickering Hale and Dorr, Kelly P. Dunbar, Samuel M.
Strongin, Joshua H. Lerner and Michael A. Mugmon for the California
Chamber of Commerce as Amicus Curiae on behalf of Defendants and
Appellants and Interveners and Appellants.

Keiter Appellate Law and Mitchell Keiter for Amicus Populi as Amicus
Curiae on behalf of Defendants and Appellants and Interveners and
Appellants.

Mayer Brown and Archis A. Parasharami for David R. Henderson,
Keith Chen, Jeffrey R. Hummel, Ethan Ligon, Michael Marlow, Lee E.
Ohanian, Damian Park, Valerie Ramey, Abbylin H. Sellers, William F.
Shughart II, Brian P. Simpson and Robert S. Taylor as Amici Curiae
on behalf of Defendants and Appellants and Interveners and
Appellants.
Jonathan M. Coupal, Timothy A. Bittle, Laura E. Dougherty and Amy
C. Sparrow for Howard Jarvis Taxpayers Association as Amicus Curiae
on behalf of Interveners and Appellants.

Olson Remcho, Robin B. Johansen, Richard R. Rios, Deborah B.
Caplan, Benjamin N. Gevercer; Altshuler Berzon, Stephen P. Berzon,
Scott A. Kronland, Stacey M. Leyton, Juhyung Harold Lee, Robin
Tholin; Service Employees International Union, Nicole G. Berner,
Steven K. Ury and Claire Presetel for Plaintiffs and Respondents.

Richard L. Hasen; Public Counsel, Mark D. Rosenbaum and Kathryn
Eidmann for California Election Law Professors as Amici Curiae on
behalf of Plaintiffs and Respondents.

Hina B. Shah; Benjamin Beach; Nayantara Mehta and Brian Chen for
Gig Workers Rising, Mobile Workers Alliance, Rideshare Drivers
United—California, We Drive Progress, A Better Balance, ACCE
Institute, Action Center on Race & the Economy, Asian Americans
Advancing Justice—Los Angeles, Bet Tzedek, California Employment
Lawyers Association, California Immigrant Policy Center, Centro
Legal de la Raza, Chinese Progressive Association, Economic Policy
Institute, Jobs With Justice Education Fund and Jobs With Justice
San Francisco, Lawyers Committee for Civil Rights of the San
Francisco Bay Area, Legal Aid at Work, Los Angeles Black Worker
Center, Maintenance Cooperation Trust Fund, National Black Worker
Center, National Council for Occupational Safety and Health, National
Domestic Workers Alliance, National Employment Law Project,
Pilipino Workers Center, PowerSwitch Action, Public Rights Project,
Santa Clara County Wage Theft Coalition, Women’s Employment
Rights Clinic of Golden Gate University School of Law and Worksafe
as Amici Curiae on behalf of Plaintiffs and Respondents.

Weinberg, Roger & Rosenfeld, David A. Rosenfeld; Daniel Ocampo,
Sally Dworak-Fisher, Laura Padin and Catherine Ruckelshaus for the
National Employment Law Project, California Labor Federation,
Rideshare Drivers United, Gig Workers Rising, Asian Americans
Advancing Justice – Asian Law Caucus, Asian Americans Advancing
Justice Southern California, PowerSwitch Action, Worksafe, Action
Center on Race & the Economy, the Economic Policy Institute, Bet
Tzedek and the California Immigrant Policy Center as Amici Curiae on
behalf of Plaintiffs and Respondents.
Bush Gottlieb, Julie Gutman Dickinson, Hector De Haro and Luke
Taylor for International Brotherhood of Teamsters, Local 396,
International Brotherhood of Teamsters, Local 542, International
Brotherhood of Teamsters, Local 848, and the Los Angeles County
Federation of Labor, AFL-CIO, as Amici Curiae on behalf of Plaintiffs
and Respondents.

David Chiu, City Attorney (San Francisco), Yvonne R. Meré, Chief
Deputy City Attorney, Sara J. Eisenberg, Matthew D. Goldberg, Ian
Eliasoph and Molly J. Alarcon, Deputy City Attorneys, Barbara J.
Parker, City Attorney (Oakland), Maria Bee, Chief Assistant City
Attorney, Zoe Savitsky and Divya Musinipally, Deputy City Attorneys,
Katherine Read, Fellowship Attorney, Michael N. Feuer, City Attorney
(Los Angeles), Kathleen Kenealy, Chief Assistant City Attorney,
Michael J. Bostrom, Assistant City Attorney, Mara W. Elliott, City
Attorney (San Diego), Mark Ankcorn, Chief Deputy City Attorney, Eric
Laguardia, Kevin King and Julie Rau, Deputy City Attorneys, Tony
Lopresti, County Counsel (Santa Clara), Kavita Narayan, Meredith A.
Johnson and Raphael N. Rajendra, Deputy County Counsel, for the
City and County of San Francisco, the Cities of Oakland and San
Diego, and the County of Santa Clara, as Amici Curiae on behalf of
Plaintiffs and Respondents.

Eric M. Overholt and Andrew W. Lockard for California Applicants’
Attorneys Association as Amicus Curiae on behalf of Plaintiffs and
Respondents.

Veena Dubal for Catherine L. Fisk, Sameer Ashar, Veena Dubal,
Charlotte Garden, Joseph Grodin, William B. Gould IV, Stephen Lee,
Sanjukta Paul, Leticia Saucedo, Reuel Schiller, Katherine Stone and
Noah D. Zatz as Amici Curiae on behalf of Plaintiffs and Respondents.

Cara L. Jenkins, Stephen Dehrer and Benjamin Herzberger for State
Senator Dave Cortese and State Assembly Member Liz Ortega as
Amici Curiae on behalf of Plaintiffs and Respondents.
Counsel who argued in Supreme Court (not intended for
publication with opinion):

Jeffrey L. Fisher
O’Melveny & Meyers LLP
2765 Sand Hill Road
Menlo Park, CA 94025
(650) 473-2633

Michael J. Mongan
State Solicitor General
455 Golden Gate Avenue, Suite 11000
San Francisco, CA 94102-7004
(415) 510-3920

Scott A. Kronland
Altshuler Berzon LLP
177 Post Street, #300
San Francisco, CA 94108
(415) 421-7151

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/10480895. Public record. Not legal advice.