Prong B Deep Dive: "Outside the Usual Course of Business"

Prong B is often the most difficult prong to satisfy and the most common reason businesses fail the ABC Test. Under Prong B, a worker can only be classified as an independent contractor if:

"The worker performs work that is outside the usual course of the hiring entity's business."

The Core Question

Ask yourself: Is this worker doing what my business does?

The Test: Would an average customer/client consider this work to be part of your core service offering? If yes, you likely fail Prong B.

How Courts Interpret "Usual Course"

Courts look at:

Industry-by-Industry Analysis

Business Type Work That Fails Prong B Work That Passes Prong B
Software Company Software development, QA testing Office cleaning, legal services, accounting
Marketing Agency Marketing campaigns, design, copywriting IT support, facilities maintenance
Delivery Company Deliveries, logistics Vehicle maintenance, HR consulting
Restaurant Cooking, serving HVAC repair, pest control
Law Firm Legal research, document review Plumbing, IT infrastructure

Case Studies

Dynamex Operations West v. Superior Court (2018)

Facts: Dynamex, a delivery company, classified its drivers as independent contractors.

Holding: FAILS Prong B - Delivery drivers perform deliveries, which is the core business of a delivery company.

Lesson: This case established the ABC Test in California and demonstrated that core service providers cannot be contractors.

Example: Tech Startup Using Contract Developers

Scenario: A SaaS startup hires contract developers to build features for their product.

Analysis: FAILS Prong B - Software development is the usual course of a software company's business, regardless of whether developers work remotely or set their own hours.

Example: Same Startup Hiring Photographer

Scenario: The same SaaS startup hires a photographer for team headshots.

Analysis: PASSES Prong B - Photography is not within the usual course of a software company's business.

Creative (But Risky) Workarounds

Some businesses try to structure around Prong B:

1. Subsidiary Structure

Create a separate legal entity that contracts workers. This is risky - courts can pierce corporate veils if the structure is deemed a sham.

2. Redefining Your Business

Some argue their business is "platform" or "marketplace" rather than the underlying service. Courts are increasingly skeptical of this argument (see Uber/Lyft litigation).

3. B2B Exemption

The business-to-business exemption may apply if all 12 criteria are met. See exemptions guide.

Practical Recommendations

  1. Audit Current Contractors: List all contractors and categorize their work
  2. Core vs. Non-Core: Identify which work is core to your business
  3. Consider Reclassification: Convert core-work contractors to employees
  4. Explore Exemptions: Some professions and B2B relationships are exempt
  5. Document Everything: Keep records showing contractor's independent business