Molina

FACTS

After Eduardo died of COVID-19 complications, Delia sued Hot Wheels, asserting wrongful death, related claims, and various Labor Code violations. She alleged the company negligently caused Eduardo to contract the illness and misclassified him as an independent contractor. During discovery, Hot Wheels served 35 special interrogatories seeking all facts supporting Delia’s claims. Delia responded with 35 identical responses, consisting of blanket objections and the following statement: “Defendants cause[d] the wrongful death of Eduardo Molina. Death resulted from dangerous and wrongful conduct of defendants, in defendant’s workplace. Defendants also failed and refused to pay wages and benefits.” Hot Wheels moved for summary judgment, contending Delia had no evidence it had negligently caused Eduardo to contract COVID-19 and the undisputed evidence showed he had been an independent contractor. Hot Wheels presented evidence that Eduardo owned and operated his own truck, was paid per load, set his own hours, could accept or decline work, and maintained his own business license. It claimed the evidence satisfied the

1 We respectfully use first names for clarity.

2 conditions of…