Petitioner Arthur Gonzales was injured on January 11, 2022, when an Uber driver (Hai Li) rear-ended his vehicle on southbound I-5 in Santa Ana. Gonzales filed suit against both the driver and Uber Technologies, Inc., alleging vicarious liability under respondeat superior and related agency theories.
On the eve of trial (February 2, 2026), the Orange County Superior Court granted Uber's motions in limine, ruling that Business and Professions Code section 7451—part of Proposition 22's labor-and-benefits framework—eliminates Uber's tort liability to third parties as a matter of law if the driver is classified as an independent contractor under that statute. The trial court's ruling barred Petitioner from presenting traditional right-to-control evidence and standard vicarious liability jury instructions.
Petitioner filed an emergency petition for writ of mandate on February 4, 2026. The Court of Appeal granted an immediate stay of all trial court proceedings on February 5, 2026, and issued an Order to Show Cause.
The central legal question is whether Proposition 22's worker classification provisions (enacted as a labor-and-benefits initiative) also function as a silent repeal of common-law tort doctrines governing Transportation Network Company liability to injured members of the public—or whether such tort theories remain available independent of the driver's employment classification.
Status: Writ proceedings pending in the California Court of Appeal, Fourth Appellate District, Division Three (Case No. G066530). Stay of trial court proceedings in effect.
