In June 2023, the Division of Occupational Safety and Health (OSHA), a state agency within the California Department of Industrial Relations, was notified by the Los Angeles County Medical Examiner (Coroner’s Office) of the death of a man who made deliveries as a driver with Uber Technologies, Inc.’s (Uber) app-based delivery platform. After efforts to arrange a meeting with Uber about the driver fatality were unsuccessful, OSHA served an administrative subpoena on Uber under Government Code section 11181, subdivision (e), and Labor Code section 6314, subdivision (c), seeking records related to the driver’s employment status and the circumstances surrounding his death. Uber responded with objections and did not produce any documents. OSHA, under Government Code section 11187, then filed this action below seeking to enforce its subpoena. The superior court granted OSHA’s petition and ordered Uber to produce all of the requested documents.
Uber appeals, arguing the trial court’s order enforcing OSHA’s administrative subpoena is invalid on numerous grounds. We affirm the order compelling production, but reverse the order to the extent it orders production of all documents without limitation, and remand to the superior court to reconsider the scope of OSHA’s requests.
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