Fernandez v. Lawson

BROWN, J., Concurring.

Based on our decision in State Compensation Ins. Fund v. Workers’ Comp. Appeals Bd. (1985) 40 Cal.3d 5 [219 Cal.Rptr. 13, 706 P.2d 1146] (State Compensation), the parties in this case assume plaintiff Miguel Fernandez is deemed the employee of homeowners Thomas and Gaile Lawson (Lawson) by operation of Labor Code1 section 2750.52 *40because Anthony’s Tree Service (ATS) was unlicensed, and Fernandez was performing work for ATS which required a contractor’s license. Were the question before us today, I would conclude State Compensation was wrongly decided and section 2750.5 has no such effect.

BACKGROUND

Section 2750.5 creates a rebuttable presumption affecting the burden of proof that a worker performing services for which a contractor’s license is required, or who is performing such services for a person who is required to obtain such a license, is an employee rather than an independent contractor. (§ 2750.5.) Proof of independent contractor status includes satisfactory proof of the factors delineated in subdivisions (a), (b), and (c). The penultimate paragraph in section 2750.5 provides, “In addition to the factors contained in subdivisions (a), (b), and (c), any person performing any function or activity for which a license is required pursuant to Chapter 9 (commencing with Section 7000) of Division 3 of the Business and Professions Code shall hold a valid contractors’ license as a condition of having independent contractor status.”

In State Compensation, supra, 40 Cal.3d 5, a ranch owner hired an unlicensed contractor (id. at p. 8) to “construct a bedroom and a bath in the attic of his ranch house with a stairway providing access” (id. at p. 7). The contractor fell from a scaffold and was rendered a quadriplegic. (Id. at p. 8.) The ranch owner, apparently not a party to the action, appeared by separate counsel in the review proceeding and argued the contractor was an employee. Similarly, in a personal injury action brought against him by the contractor, the ranch owner asserted that workers’ compensation was the contractor’s exclusive remedy. (Id. at p. 7, fn. 1.) State Compensation Insurance Fund, the ranch owner’s workers’ compensation insurer, argued the penultimate paragraph of section 2750.5 was only applicable when the worker was seeking independent contractor status and not when the worker was seeking employee status. (State Compensation, at p. 8.)

This court disagreed, in particular concluding “the penultimate paragraph establishes a fourth factor necessary to rebut the presumption” that a worker is an employee, not an independent contractor. (State Compensation, supra, 40 Cal.3d at p. 12.) “[B]y stating that a license is a condition of the status, the Legislature has unequivocally stated that the person lacking the requisite license may not be an independent contractor.” (Id. at p. 15.) Thus, while the contractor arguably otherwise satisfied the test for being an *41independent contractor, because he was unlicensed he was held to be an employee entitled to workers’ compensation benefits.3 (State Compensation, at pp. 7-8, 12-16.)

Justice Mosk filed a concurring opinion, expressing his “concern about the unfair burden effectively imposed on a class of hirers” by Labor Code section 2750.5. (State Compensation, supra, 40 Cal.3d at p. 16 (conc. opn. of Mosk, J.).) He noted that “Insurance Code section 11590 requires comprehensive personal liability insurance policies to contain a provision for compensation insurance for ‘employees,’ as that term is defined in Labor Code section 3351, subdivision (d); [section 3352, subdivision (h),] however, expressly excludes, among others, any person employed for less than 52 hours during the 90 calendar days immediately preceding the date of the injury [citation]. Thus, policies drawn to incorporate [Insurance Code] section 11590 effectively fail to provide compensation insurance in the apparently common situation in which workers are engaged in fairly routine and minor repairs rather than major capital improvements.” (State Compensation, at pp. 17-18.) Justice Lucas dissented, adopting the Court of Appeal opinion below, and concluding the language in Labor Code section 2750.5’s penultimate paragraph simply meant that the contractor (as opposed to the ranch owner) could not assert independent contractor status unless he had a contractor’s license. (State Compensation, at pp. 18-23 (dis. opn. of Lucas, J.).)

DISCUSSION

In State Compensation, supra, 40 Cal.3d 5, we did not consider the broader implications of concluding the homeowner was an employer under section 2750.5, perhaps because we were only focusing on workers’ compensation coverage, and the homeowner had that coverage available. Here, while Lawson paid premiums for workers’ compensation coverage, Fernandez fell outside the coverage provisions of workers’ compensation by virtue of the *42number of hours worked. Therefore, unlike the homeowner in State Compensation, whose “employee” came within the coverage provisions of workers’ compensation and workers’ compensation was his exclusive remedy, Lawson is subject to civil liability as an employer.

Of course, the ramifications of placing employer status on unsuspecting homeowners hiring workers to do a discrete task the homeowner might never suspect would require a contractor’s license are dramatic. Presumably, in the absence of any exclusion under the applicable law, homeowners become potentially liable not only for OSHA compliance, but COBRA health coverage benefits, sexual harassment claims, collective bargaining agreement enforcement, and a myriad of other obligations they are ill-equipped to anticipate or comply with. It seems unlikely the Legislature intended this result when it enacted section 2750.5.

Rather, it appears Justice Lucas and the Court of Appeal in State Compensation were correct that the language in section 2750.5’s penultimate paragraph simply means that the contractor, as opposed to the homeowner, is precluded from asserting independent contractor status if he is not licensed.4

As can be seen, section 2750.5, subdivision (c) already includes “holding a license pursuant to the Business and Professions Code” as one of the many cumulative factors to consider in determining whether the worker’s independent contractor status is bona fide. It seems unlikely the Legislature nevertheless singled out this factor as a kind of “trump card,” the absence of which *43renders a worker an employee despite any other evidence of independent contractor status. Moreover, if the Legislature had intended the penultimate paragraph to be part of the criteria for rebutting the presumption a worker was an employee, it presumably would have made “having a license” factor (d), along with the other three factors, not listed it in a different paragraph. Further, it would have deleted the reference in subdivision (c) to licensing.

Along these lines, the legislative history of section 2750.5 states, “Three basic factors would have to be proved to show independent contractor status under this bill . . . .” (Sen. Industrial Relations Com., Analysis of Assem. Bill No. 3429 (1977-1978 Reg. Sess.) Aug. 14, 1978, p. 2, italics added.) The analysis then summarizes the factors currently in section 2750.5, subdivisions (a) through (c). (Sen. Industrial Relations Com., Analysis of Assem. Bill No. 3429, supra, p. 2.) “Finally, this bill would require any contractor performing any function or activity for which a license is required from the Contractors’ State Licensing Board to hold the required license as a condition of having independent contractor status.” (Ibid.) In addition, the legislative history shows the bill was originally amended to read, “In addition to subdivisions (a), (b) and (c), any person claiming an independent contractor status shall have, in his possession, a valid contractor’s license issued pursuant to the provisions contained in Chapter 9 (commencing with Section 7000) of Division 3 of the Business and Professions Code.” (Assem. Bill No. 3429 (1977-1978 Reg. Sess.) as amended Aug. 7, 1978.)

Indeed, the legislative history of section 2750.5 indicates the Legislature was concerned contractors were improperly characterizing those they hired as independent contractors instead of employees and thereby denying them union scale pay, and workers’ compensation and unemployment insurance benefits. (Enrolled Bill Rep. on Assem. Bill No. 3429 (1977-1978 Reg. Sess.) Sept. 12, 1978, p. 1 [“The need for this legislation stems from work agreements in the construction industry that tend to undermine collective bargaining agreements by using the guise of independent contractor to cover work that is normally done by employees, thus avoiding payment of union scale, workers compensation insurance and fringe benefits”]; Sen. Floor Statement, Assem. Bill No. 3429 (1977-1978 Reg. Sess.) p. 1 [“This legislation is needed because of the huge increase in the number of contractors who are treating their employees as independent subcontractors in order to illegally escape payment of employee U[nemployment] Insurance] taxes, benefits, workers’ compensation premiums, and other costs associated with employees. This situation is totally unfair and is competitively killing the honest contractor who plays by the rules”].) There is no indication in the legislative history the Legislature intended section 2750.5 to apply to a homeowner who hires an unlicensed contractor. (Sen. Floor Statement, Assem. Bill No. 3429 (1977-1978 Reg. Sess.) p. 2 [“This bill only covers construction workers and doesn’t cover other employers or employees”].) *44Indeed, a contractor or construction worker would reasonably be expected to be familiar with licensing and safety law requirements, whereas the average homeowner would not.

Moreover, the State Compensation analysis leads to several anomalous results. As alluded to by Justice Lucas in his State Compensation dissent, in concluding the homeowner is an employer, we are providing either workers’ compensation or tort recovery to a worker who committed a misdemeanor in performing unlicensed contracting work, but not providing such coverage or recovery to a contractor who actually complied with the law. (State Compensation, supra, 40 Cal.3d at p. 21.) This is “inconsistent with the purpose of the licensing laws.” (Ibid.) Similarly, we create the ironic situation that while the homeowner, Lawson, did not have to pay Lascano, doing business as Anthony’s Tree Service, because he was unlicensed (Bus. & Prof. Code, § 7031), Lawson is deemed his employer under section 2750.5, with concomitant workers’ compensation or tort liability, because Lascano was unlicensed. And, most important, despite the fact that the legislative history of section 2750.5 never hints the statute would apply to a homeowner, we expose unsuspecting homeowners to a panoply of obligations the homeowner is likely unaware of and with which they have little ability to comply. This cannot be a proper interpretation of section 2750.5, and the Legislature should act promptly, by deleting or amending the penultimate paragraph of section 2750.5, to restore an apparently straightforward intent which has been undermined by the section’s garbled syntax.

Baxter, J., concurred.

All statutory references are to the Labor Code unless otherwise indicated.

Section 2750.5 provides: “There is a rebuttable presumption affecting the burden of proof that a worker performing services for which a license is required pursuant to Chapter 9 (commencing with Section 7000) of Division 3 of the Business and Professions Code, or who is performing such services for a person who is required to obtain such a license is an employee rather than an independent contractor. Proof of independent contractor status includes satisfactory proof of these factors:

“(a) That the individual has the right to control and discretion as to the manner of performance of the contract for services in that the result of the work and not the means by which it is accomplished is the primary factor bargained for.

“(b) That the individual is customarily engaged in an independently established business.

“(c) That the individual’s independent contractor status is bona fide and not a subterfuge to avoid employee status. A bona fide independent contractor status is further evidenced by the presence of cumulative factors such as substantial investment other than personal services in the business, holding out to be in business for oneself, bargaining for a contract to complete a specific project for compensation by project rather than by time, control over the time and place the work is performed, supplying the tools or instrumentalities used in the work other than tools and instrumentalities normally and customarily provided by employees, hiring employees, performing work that is not ordinarily in the course of the principal’s work, performing work that requires a particular skill, holding a license pursuant to the Business and Professions Code, the intent by the parties that the work relationship is of an independent contractor status, or that the relationship is not severable or terminable at will by the principal but gives rise to an action for breach of contract.

“In addition to the factors contained in subdivisions (a), (b), and (c), any person performing any function or activity for which a license is required pursuant to Chapter 9 (commencing with Section 7000) of Division 3 of the Business and Professions Code shall hold a valid contractors’ license as a condition of having independent contractor status.

“For purposes of workers’ compensation law, this presumption is a supplement to the existing statutory definitions of employee and independent contractor, and is not intended to lessen the coverage of employees under Division 4 and Division 5.”

(See, e.g., Hunt Bldg. Corp. v. Bernick (2000) 79 Cal.App.4th 213, 216, 220 [93 Cal.Rptr.2d 883] [general contractor liable for unlicensed subcontractors’ employees’ unpaid unemployment insurance and other contributions and withholding taxes by operation of § 2750.5]; Rosas v. Dishong (1998) 67 Cal.App.4th 815, 817, 821-823, 826 [79 Cal.Rptr.2d 339] [tree trimmer who worked too few hours to qualify for workers’ compensation benefits still an employee by operation of § 2750.5 for purposes of tort liability; homeowner not liable under California’s Occupational Safety and Health Act (OSHA) (§ 6300 et seq.) due to “household domestic service” exception]; Foss v. Anthony Industries (1983) 139 Cal.App.3d 794, 797-800 [189 Cal.Rptr. 31] [§ 2750.5 applies in tort actions by third parties against hirer of unlicensed contractor regarding torts by unlicensed contractor’s employee, but licensing requirement not retroactive]; but see Fillmore v. Irvine (1983) 146 Cal.App.3d 649, 657 [194 Cal.Rptr. 319] [Lab. Code, § 2750.5 does not apply to determinations of whether a person is an employee or independent contractor under Bus. & Prof. Code, § 7031, which in general bars actions to collect compensation by unlicensed contractors].)

Under this approach, Eliseo Lascano, doing business as ATS, is initially presumed to be Lawson’s employee. (§ 2750.5 [“There is a rebuttable presumption affecting the burden of proof that a worker performing services for which a license is required ... is an employee rather than an independent contractor”].) However, that presumption is rebutted by overwhelming evidence that Lascano satisfied the criteria for being an independent contractor delineated in subdivisions (a), (b), and (c). For example, Lascano had “the right to control and discretion as to the manner of performance of the contract for services,” was “customarily engaged in an independently established business,” had a “substantial investment other than personal services in the business,” held himself “out to be in business for [hinfjself,” “bargainfed] for a contract to complete a specific project for compensation by project rather than by time,” exercised “control over the time and place the work [was] performed,” “supplied] the tools or instrumentalities used in the work,” “luffed] employees,” “perform[ed] work that [was] not ordinarily in the course of the principal’s work,” and “perfornffed] work that requirefd] a particular skill.” (§ 2750.5, subds. (a), (b), (c).)

Furthermore, under this approach, Fernandez is presumed an employee of Lascano, and that presumption is not rebutted by the criteria inparagraphs (a), (b), or (c). (§ 2750.5 [“There is a rebuttable presumption affecting the burden of proof that a worker . . . who is performing such services for a person who is required to obtain such a license is an employee rather than an independent contractor”].) Neither Lascano nor Fernandez is rendered an employee of Lawson by virtue of the penultimate paragraph of section 2750.5. Rather, this paragraph simply means that the contractor is precluded from asserting independent contractor status if he is not licensed.