University of Michigan Law School
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Case Name Narayan v. EGL, Inc. EE-CA-0343
Docket / Court 5:05-cv-04181 ( N.D. Cal. )
State/Territory California
Case Type(s) Equal Employment
Case Summary
On September 12, 2005, three freight pickup and delivery drivers, who worked for EGL, Inc., filed a class action lawsuit under the California Labor Code and the California Unfair Competition Law against EGL in the Santa Clara Superior Court of California. On October 14, 2005, the case was removed ... read more >
On September 12, 2005, three freight pickup and delivery drivers, who worked for EGL, Inc., filed a class action lawsuit under the California Labor Code and the California Unfair Competition Law against EGL in the Santa Clara Superior Court of California. On October 14, 2005, the case was removed to the United States District Court Northern District of California, San Jose on grounds of diversity jurisdiction.

The Plaintiffs, represented by private counsel, asked the court for damages and declaratory relief, claiming that EGL denied them certain employee benefits required under the California Labor Code by misclassifying them as independent contractors instead of employees. Specifically, the Plaintiff's alleged that EGL violated the California Unfair Competition Law (Cal. Business and Profession Code §17200-09) by misclassifying the Plaintiffs as independent contractors and thereby violated state laws requiring employers to pay overtime compensation (Cal. Lab. Code §§ 510 & 1194) and minimum wages (Cal. Lab. Code §1182.11 & 1182.12), prohibiting employers from making certain improper deductions from wages (Cal. Lab. Code § 221), requiring employers to reimburse employees for necessary business expenses (Cal. Lab. Code § 2802), requiring employers to provide accurate itemized wage statements to employees (Cal. Lab. Code §1174 & 1174.5), requiring employers to pay all compensation to employers that are discharged (Cal. Lab. Code §201, 202, & 203) and requiring employers to provide off-duty meal periods (Cal. Lab. Code §§ 226.7 & 512).

EGL, Inc. is a global transportation, supply chain management and information services company incorporated under the laws of Texas and headquartered in California. One aspect of EGL's business is domestic delivery services. The Plaintiffs were California residents who provided freight pick-up and delivery services for EGL in California. All three Plaintiffs signed agreements with EGL that expressly characterized the Plaintiffs as independent contractors and included a choice of law clause specifying Texas law as governing the agreement.

On December 8, 2006, EGL moved for summary judgment arguing that the Plaintiffs were independent contractors under the terms of the agreement, and therefore not entitled to employee benefits provided by the California Labor Code. The Plaintiff's argued that their claims fell outside the scope of the choice of law provision and that the application of Texas law is contrary to California law. The District Court (Judge Ronald M. Whyte) granted summary judgment for the Defendant. Narayan v. EGL, Inc., No. C 05 04181, 2007 WL 2021809 (N.D.Cal. July 10, 2007).

On July 13, 2010, the United States Court of Appeals, Ninth Circuit (Judge Edward R. Korman) reversed the District Court order granting summary judgment. Narayan v. EGL, Inc., 616 F.3d 895 (9th Cir. 2010). The court reviewed the District Court's choice of law decision de novo, and held that Texas law applied only to the interpretation and enforcement of the contract itself. Id. at 899. Therefore, California law applied, because the Plaintiffs claimed benefits under the California Labor Code. Furthermore, the court held that summary judgment was not appropriate under California's multi-faceted test of employment, because a reasonable jury could find the existence of an employee relationship between the Plaintiffs and EGL. Id. at 904.

The case is ongoing.

Joe Reiter - 03/29/2011


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Issues and Causes of Action
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Issues
Defendant-type
Transportation
Discrimination-area
Other Conditions of Employment (including assignment, transfer, hours, working conditions, etc)
Pay / Benefits
Plaintiff Type
Private Plaintiff
Causes of Action State law
Defendant(s) EGL, Inc.
Plaintiff Description Plaintiffs are freight pickup and delivery drivers who were denied employee benefits provided by the California Labor Code
Indexed Lawyer Organizations None on record
Class action status sought Yes
Class action status granted Pending
Prevailing Party None Yet / None
Public Int. Lawyer No
Nature of Relief None yet
Source of Relief None yet
Form of Settlement None on record
Order Duration not on record
Case Closing Year n/a
Case Ongoing Yes
Additional Resources
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Case Studies Megacases, Diversity, and the Elusive Goal of Workplace Reform
Written: Mar. 01, 2008
By: Nancy Levit (University of Missouri-Kansas City School of Law)
Citation: 49 B.C. L. Rev. 367 (2008)
[ Detail ] [ External Link ]

  Second Generation Employment Discrimination: A Structural Approach
By: Susan Sturm (Columbia Law School)
Citation: 101 Colum. L. Rev. 458 (2001)
[ Detail ] [ External Link ]

Docket(s)
5:05-cv-4181 (N.D. Cal.) 03/07/2011
EE-CA-0343-9000 PDF | Detail
PACER [Public Access to Court Electronic Records]
General Documents
DEFENDANT EGL, INC.’S MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF ITS MOTION FOR SUMMARY JUDGMENT ON PLAINTIFF MOHIT NARAYAN’S INDIVIDUAL CLAIMS 12/08/2006
EE-CA-0343-0001 PDF | Detail
Document Source: PACER [Public Access to Court Electronic Records]
DEFENDANT EGL, INC.’ S MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF ITS MOTION FOR SUMMARY JUDGMENT REGARDING THE INDIVIDUAL CLAIMS OF PLAINTIFF HANNA RAHAWI 12/08/2006
EE-CA-0343-0002 PDF | Detail
Document Source: PACER [Public Access to Court Electronic Records]
DEFENDANT EGL, INC.’S MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF ITS MOTION FOR SUMMARY JUDGMENT ON THE INDIVIDUAL CLAIMS OF PLAINTIFF THOMAS HEATH 12/08/2006
EE-CA-0343-0003 PDF | Detail
Document Source: PACER [Public Access to Court Electronic Records]
PLAINTIFFS-APPELLANTS' OPENING BRIEF 05/08/2008
EE-CA-0343-0004 PDF | Detail
Document Source: Westlaw
ORDER GRANTING DEFENDANT'S MOTIONS FOR SUMMARY JUDGMENT ON PLAINTIFFS' INDIVIDUAL CLAIMS 07/10/2010 (2007 WL 2021809 / 2007 U.S.Dist.LEXIS 50465) (N.D. Cal.)
EE-CA-0343-0007 PDF | WESTLAW| LEXIS | Detail
Document Source: Westlaw
Opinion 07/13/2010 (616 F.3d 895)
EE-CA-0343-0006 PDF | WESTLAW| LEXIS | External Link | Detail
Document Source: Google Scholar
SECOND AMENDED COMPLAINT 02/07/2011
EE-CA-0343-0005 PDF | Detail
Judges Hawkins, Michael Daly (Ninth Circuit)
EE-CA-0343-0006
Korman, Edward Robert (E.D.N.Y.)
EE-CA-0343-0006
Lloyd, Howard R. (N.D. Cal.) [Magistrate]
EE-CA-0343-9000
Thomas, Sidney Runyan (Ninth Circuit)
EE-CA-0343-0006
Whyte, Ronald M. (N.D. Cal.)
EE-CA-0343-0007 | EE-CA-0343-9000
Monitors/Masters None on record
Plaintiff's Lawyers Cervantez, Eve Hedy (California)
EE-CA-0343-0005 | EE-CA-0343-9000
Grindstaff, Lorraine (California)
EE-CA-0343-0005 | EE-CA-0343-9000
Kaufmann, Aaron D (California)
EE-CA-0343-0004 | EE-CA-0343-0005 | EE-CA-0343-9000
Leyton, Stacey M. (California)
EE-CA-0343-0004 | EE-CA-0343-0005
Murray, Matthew J (California)
EE-CA-0343-0005 | EE-CA-0343-9000
Pogrel, David Philip (California)
EE-CA-0343-0004 | EE-CA-0343-0005 | EE-CA-0343-9000
Rubin, Michael (California)
EE-CA-0343-0004 | EE-CA-0343-0005 | EE-CA-0343-9000
Sandford, Jules (California)
EE-CA-0343-9000
Smullin, Rebecca (California)
EE-CA-0343-0004
Defendant's Lawyers Burror, Heather (California)
EE-CA-0343-0001 | EE-CA-0343-0002 | EE-CA-0343-0003 | EE-CA-0343-9000
Elmore, Allison H (California)
EE-CA-0343-9000
Jacobs, Bruce (California)
EE-CA-0343-0001 | EE-CA-0343-0002 | EE-CA-0343-0003
Kubin, Karen Joyce (California)
EE-CA-0343-0001 | EE-CA-0343-0002 | EE-CA-0343-0003 | EE-CA-0343-9000
McAlpine, Fraser A. (Texas)
EE-CA-0343-9000
Suh, Yeongyo Anna (California)
EE-CA-0343-9000
Vizas, Jill (California)
EE-CA-0343-0001 | EE-CA-0343-0002 | EE-CA-0343-0003
Other Lawyers None on record

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