United States District Court, N.D. Iowa, Cedar Rapids Division
Williams United States District Judge
matter is before the Court on cross motions for a
determination of the applicable body of law. (Docs. 69, 70).
The parties timely filed resistances to the opposing
party's motion. (Docs. 73, 74; see also Doc. 67
(setting scheduling order deadlines, including the deadlines
for briefing the choice of law issues)). For the following
reasons, the Court finds that Iowa law is to govern this
PROCEDURAL AND FACTUAL BACKGROUND
CRST Expedited is a trucking company based out of Cedar
Rapids, Iowa, and defendant CRST International is an
affiliated company. (Doc. 70-1, at 8). Plaintiff formerly
worked as part of a two-person, long-haul truck driving team
for defendants, first as an “employee, ” then
later as an “independent contractor.” (Doc. 75,
at 3, 8-9). Although plaintiff signed an independent
contractor agreement with defendants, plaintiff now argues
that he was misclassified as an independent contractor and,
instead, should have been classified as an employee. (Doc.
75, at 12-13). The independent contractor agreement that
plaintiff signed included both a forum selection clause and a
choice of law provision. (Doc. 70-2, at 30).
operative complaint in this case was initially filed in the
Superior Court of California, and plaintiff brought ten
claims “on behalf of himself, all others similarly
situated, and the general public.” (Doc. 75, at 2).
All of the claims are based on California law: 1)
misclassification of employee as independent contractor, Cal.
Lab. Code § 226.8; 2) failure to pay meal and rest
period compensation, Cal. Lab. Code §§ 226.7, 512;
3) failure to pay compensation for all hours worked and
minimum wage violations, Cal. Lab. Code §§ 216,
1194, 1194.2, 1197; 4) failure to provide accurate itemized
statements, Cal. Lab. Code §§ 226, 226.2; 5)
waiting time penalties, Cal. Lab. Code, § 203; 6)
failure to pay all wages by the appropriate pay period, Cal.
Lab. Code § 204; 7) failure to reimburse business
expenses, Cal. Lab. Code § 2802; 8) failure to pay
minimum wage and rest and recovery period compensation
separate from any piece-rate compensation, Cal. Lab. Code
§ 226.2; 9) Private Attorneys General Act, Cal. Lab.
Code §§ 2698, et. seq.; and 10) unfair
business practices, Cal. Bus. & Prof. Code §§
17200, et. seq. (See Doc. 75).
removed this case to the United States District Court for the
Central District of California and asserted diversity
jurisdiction as the basis for the federal court's
jurisdiction. (Doc. 1). Defendants subsequently filed a
motion to transfer venue. (Doc. 31). The Central District of
California found that the forum selection clause contained in
the independent contractor agreement was valid and
enforceable and, based on the forum selection clause,
transferred the case to this Court. (Doc. 35).
parties agree that this case presents the potential for a
conflict of laws issue. Specifically, plaintiff contends that
California law governs, and defendants contend that Iowa law
governs. Plaintiff asserts that the parties are in agreement
that the choice of law clause in the independent contractor
agreement is inapplicable to this case (Doc. 69, at 11 n.1),
and defendants do not argue for application of the choice of
law provision (see Doc. 70-1, at 17 (arguing that
the choice of law provision indicates that the parties
expected Iowa law to govern disputes regarding the
parties' contractual relationship, but not arguing for
strict application of the choice of law provision)). At the
parties' request, the Court set a briefing schedule for
the parties to follow in briefing the conflict of laws issue.
(Doc. 67). The parties timely filed their briefs in
accordance with that schedule.
determine which body of law applies to a dispute, a court
must apply the conflict of laws rules of the state in which
it sits. Klaxon Co. v. Stentor Elec. Mfg. Co., 313
U.S. 487, 496-97 (1941). This holds true even when, pursuant
to a valid forum selection clause, a case is transferred to a
district other than the one in which it was originally filed.
Atl. Marine Constr. Co. v. U.S. Dist. Court for the W.
Dist. of Tex., 571 U.S. 49, 64-66 (2013). When
confronted with a potential conflict of laws issue, the first
step is to determine whether there is a “true
conflict” between the different bodies of law that
could govern. Phillips v. Marist Soc'y of Wash.
Province, 80 F.3d 274, 276 (8th Cir. 1996). If there is
no difference in the relevant laws of the different states,
the conflict is a false conflict that need not be resolved.
Baron v. Ford Motor Co. of Can. Ltd., 965 F.2d 195,
197 (7th Cir. 1992); see also Leonards v. S. Farm Bureau
Cas. Ins. Co., 279 F.3d 611, 612 (8th Cir. 2002)
(declining to resolve a conflict of laws issue where the
conflict was a “false conflict”).
cases, Iowa applies the Restatement (Second) Conflict of
Laws' “most significant relationship”
test in considering conflict of laws issues. Veasley v.
CRST Int'l, Inc., 553 N.W.2d 896, 897 (Iowa 1996).
The Restatement provides as follows:
(1) The rights and liabilities of the parties with respect to
an issue in tort are determined by the local law of the state
which, with respect to that issue, has the most significant
relationship to the occurrence and the parties under the
principles stated in § 6.
(2) Contacts to be taken into account in applying the
principles of § 6 to determine the law applicable to an
(a) the place where the injury occurred,
(b) the place where the conduct causing the injury occurred,
(c) the domicil, residence, nationality, place of
incorporation and place of business of the parties, and
(d) the place where the relationship, if any, between the
parties is centered.
These contacts are to be evaluated according to their
relative importance with respect to the particular issue.
(Second) of Conflict of Laws § 145 (Am. Law. Inst.
2018). Section 6 of the Restatement, as referred to
in Section 145, reads as follows:
(1) A court, subject to constitutional restrictions, will
follow a statutory directive of its own state on choice of
(2) When there is no such directive, the factors relevant to
the choice of the applicable rule of law include
(a) the needs of the interstate and international systems,
(b) the relevant policies of the forum,
(c) the relevant policies of other interested states and the
relative interests of those states in the determination of
the particular issue,
(d) the protection of justified expectations,
(e) the basic policies underlying the particular field ...