Moreno v. C.H. Robinson Worldwide, Inc.

Background

Carlos Moreno brought a putative class action against C.H. Robinson Worldwide, Inc., C.H. Robinson Company, and various Doe defendants. The opinion collectively calls the two C.H. Robinson entities “CHR.” Moreno alleged that CHR misclassified truck drivers as independent contractors and failed to provide meal and rest breaks, reimburse business expenses, provide accurate and timely wage statements, and pay minimum wages. He asserted claims under the California Labor Code and California’s Unfair Competition Law.

CHR moved for judgment on the pleadings and moved to strike Moreno’s class allegations. The court granted in part and denied in part both motions, with leave to amend.

Employment Relationship

The court held that Moreno plausibly alleged that CHR employed him. California’s employment test focuses on factors such as control over wages, hours, and working conditions, whether the worker was permitted to work, and whether a common-law employment relationship existed. Moreno alleged that the defendants employed the drivers, set their compensation, paid them on a piece-rate basis, and had power to control their wages, hours, and working conditions. He also alleged that the two CHR entities jointly employed him. The court found those allegations sufficient at the pleading stage.

The court rejected CHR’s argument that it could not be Moreno’s employer because it was a freight broker rather than a motor carrier. The court said that California uses a functional test focused on control, rather than a formal test based on registration, trucking assets, or direct contracts with drivers.

Class Allegations

The court denied the motion to strike the class allegations. It concluded that CHR’s arguments about commonality and typicality were premature because class-certification proceedings were the more appropriate time to address them. Information about CHR’s policies, its dealings with drivers, and the uniformity of employment terms was within CHR’s control and could be developed through discovery.

Claims 1–3

The court held that Moreno did not plead sufficient facts for his meal-break, rest-break, and minimum-wage claims. For the break claims, he alleged generally that drivers worked long hours, lacked adequate breaks, and were encouraged to complete jobs quickly. But he did not identify when, how, or to whom the alleged denials occurred, or identify a specific instance when he was denied a required break.

For the minimum-wage claim, Moreno identified unpaid activities such as pre- and post-trip inspections, waiting, and time spent on over-the-road trips. The court nevertheless found that he did not identify at least one workweek in which he was not paid the minimum wage, or provide facts about when and how often the unpaid work occurred, how long it took, or how it should have been compensated.

Claims 4 and 5

The court held that Moreno’s claim under California Labor Code section 226 for inaccurate wage statements failed because it depended on the inadequately pleaded wage and break claims.

The court also held that his section 204 claim failed. Section 204 regulates when wages must be paid; it does not create a right to a particular type or amount of wages. Therefore, Moreno could not base that claim solely on an allegation that CHR underpaid him.

Claim 6

The court held that Moreno adequately pleaded his claim for unreimbursed business expenses under California Labor Code section 2802. He alleged that he paid for fuel and insurance that CHR did not reimburse. Although the complaint did not expressly say that these expenses were part of his job duties or that CHR knew about them, the court found that such an inference was reasonable given his alleged role as a truck driver.

Unfair Competition Law Claim

The court dismissed Moreno’s Unfair Competition Law claim in its entirety. The court explained that private claims under that law provide equitable remedies—restitution and injunctions—and require the plaintiff to show that money damages are inadequate. Moreno did not allege how restitution under that law would provide anything beyond damages potentially available under the Labor Code.

The court also rejected the request for injunctive relief because Moreno did not adequately allege that he was still employed by CHR and therefore likely to suffer future harm. Without a basis for Moreno himself to seek an injunction, he could not represent a class seeking that relief.

Disposition

The court granted in part and denied in part CHR’s motion for judgment on the pleadings and motion to strike. The dismissed claims may be amended: the court granted leave to amend because this was Moreno’s first opportunity to correct the identified deficiencies and the record did not establish that amendment would necessarily be futile. Moreno was permitted to file a first amended complaint by August 14, 2025, and could not add new claims or otherwise amend without court permission or the parties’ agreement. The court also denied as moot CHR’s requests for judicial notice concerning whether CHR was registered as a motor carrier and other submitted materials.