Beaumont-Jacques v. Farmers Group: Insurance Company District Manager Was Independent Contractor

Just a quick note on this somewhat unusual case. In Beaumont-Jacques v. Farmers Group, Inc. (6/12/13, pub. 7/11/13) --- Cal.App.4th ---, the plaintiff worked for the defendant insurance companies ("Signatory Defendants") as a district manager. She "recruited and recommended persons to become agents solely for the Signatory Defendants; if the latter accepted such a person, [plaintiff] trained and motivated that agent to market only the Signatory Defendants' insurance products. While she herself did not sell those products, Appellant could represent Respondents, but no other insurers." 

The plaintiff filed an action for Labor Code and other violations, alleging that the defendants improperly treated her as an independent contractor, rather than as an employee.  The trial court granted the defendants' motion for summary judgment, and the Court of Appeal affirmed: 

The record below demonstrates that Appellant exercised meaningful discretion with reference to her efforts. While Respondents had input over the quality and direction of those efforts, they did not have sufficient “control of the details” with respect to those efforts. Appellant was thus an independent contractor and all of her claims must fail. 

Slip op. at 1. 

The opinion is available here.