Brown v. DoorDash
- Martinez-Olguin
- 4:25-cv-10817
- U.S. District Court · Northern District of California
- 6
Counsel of record per CourtListener. Firm names are approximate and have been consolidated across spelling variants.
In Alfonso Brown v. DoorDash, Judge Martinez-Olguin remanded the case because federal jurisdiction was lacking, without deciding the workers’ claims.
Miles Richardson and the remaining claims against DoorDash are affected. The case proceeds, if at all, in Alameda County Superior Court rather than federal court; the opinion did not decide the underlying employment or labor-law claims. Alfonso Brown’s claims had already been voluntarily dismissed.
What happened
In Alfonso Brown, et al. v. DoorDash, Inc., Miles Richardson alleged that DoorDash improperly treated delivery drivers as independent contractors instead of employees. He sought civil penalties under California labor law and a declaration about Proposition 22, including whether federal law overrides it. Alfonso Brown’s claims had already been voluntarily dismissed.
DoorDash asked the federal court to dismiss Richardson’s remaining claims. The court instead examined whether it had authority to hear the case. It concluded that Richardson’s claims did not necessarily require deciding the federal-law question about whether Proposition 22 is overridden, because the court would first need to determine whether DoorDash satisfied Proposition 22’s requirements.
Judge Martinez-Olguin ruled that the federal court lacked subject-matter jurisdiction. The court remanded the case to Alameda County Superior Court, ordered the file sent there, and closed the federal case. It did not decide whether DoorDash misclassified the drivers or whether DoorDash violated California labor law.
The detailed version
- Brown v. DoorDash · No. 4:25-cv-10817
- Martinez-Olguin
- Sept. 10, 2026
Background
DoorDash provides delivery services through drivers commonly called “dashers.” The complaint alleged that DoorDash controlled how dashers performed deliveries, monitored their performance, set their pay, and could impose consequences for declining orders or failing to follow instructions. Miles Richardson alleged that he and other dashers were employees rather than independent contractors and that DoorDash violated various California Labor Code requirements, including rules concerning minimum wages, payment for all hours worked, expense reimbursement, meal and rest periods, and wage statements.
Richardson asserted two claims: a claim under California’s Private Attorneys General Act for civil penalties on behalf of similarly affected workers, and a claim seeking a declaration that DoorDash did not satisfy Proposition 22’s requirements for treating app-based drivers as independent contractors. He also alleged that, even if DoorDash satisfied those requirements, Proposition 22 was overridden by the Federal Aviation Administration Authorization Act. The case had been removed from Alameda County Superior Court. Alfonso Brown’s claims were later voluntarily dismissed, leaving Richardson’s claims.
DoorDash moved to dismiss Richardson’s claims under Rule 12(b)(6), which concerns whether a complaint states a legally sufficient claim. Before deciding that motion, the court raised the separate issue of subject-matter jurisdiction, meaning the federal court’s legal authority to hear the case, and requested additional briefing.
Jurisdictional analysis
DoorDash relied on federal-question jurisdiction and supplemental jurisdiction. The court explained that a state-law claim may sometimes be heard in federal court when it necessarily raises a substantial and disputed federal issue. DoorDash argued that federal jurisdiction existed because the case required deciding whether the Federal Aviation Administration Authorization Act preempted, or overrode, Proposition 22.
The court rejected that argument. Richardson first alleged that DoorDash failed to satisfy Proposition 22’s statutory preconditions. The court reasoned that this factual question would have to be resolved before any preemption question. If DoorDash had not satisfied Proposition 22’s preconditions, the court would not need to decide whether federal law preempted the statute. Therefore, the federal issue was not an essential element of Richardson’s claims and did not establish federal-question jurisdiction.
Ruling
The court concluded that it lacked subject-matter jurisdiction. It did not reach the merits of Richardson’s worker-classification, California Labor Code, Proposition 22, or federal-preemption claims, and it did not decide DoorDash’s Rule 12(b)(6) motion. Judge Araceli Martinez-Olguin remanded the case to Alameda County Superior Court, directed the Clerk of Court to transmit the file there, and ordered the federal case closed.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.