California Codes

Cal. Labor Code § 925 (2026)

✓ current as of May 2026

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(a)An employer shall not require an employee who primarily resides and works in California, as a condition of employment, to agree to a provision that would do either of the following:

(1)Require the employee to adjudicate outside of California a claim arising in California.

(2)Deprive the employee of the substantive protection of California law with respect to a controversy arising in California.

(b)Any provision of a contract that violates subdivision (a) is voidable by the employee, and if a provision is rendered void at the request of the employee, the matter shall be adjudicated in California and California law shall govern the dispute.

(c)In addition to injunctive relief and any other remedies available, a court may award an employee who is enforcing his or her rights under this section reasonable attorney’s fees.

(d)For purposes of this section, adjudication includes litigation and arbitration.

(e)This section shall not apply to a contract with an employee who is in fact individually represented by legal counsel in negotiating the terms of an agreement to designate either the venue or forum in which a controversy arising from the employment contract may be adjudicated or the choice of law to be applied.

(f)This section shall apply to a contract entered into, modified, or extended on or after January 1, 2017.

Notes of Decisions

Cited in 90 cases (69 in the last 5 years), 2018–2026 · leading case: Oxford Global Res., LLC v. Hernandez, 106 N.E.3d 556 (Mass. 2018).

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Oxford Global Res., LLC v. Hernandez, 106 N.E.3d 556 (Mass. 2018). · cites it 4× “First, the California Legislature recently enacted Cal. Lab. Code § 925 , which prohibits employers from requiring employees who primarily reside and work in California, as a condition of employment, to agree to a provision in an employment agreement that would require the…”

Fleming v. Matco Tools Corp., 384 F. Supp. 3d 1124 (N.D. Cal. 2019). · cites it 6× “5 is dispositive of this motion, I need not address the parties' arguments related to California Labor Code § 925. Additionally, because Fleming's proposed sur-reply is dedicated to argument related to California Labor Code § 925, it is not needed and Fleming's Objection to…”

Depuy Synthes Sales, Inc. v. Howmedica Osteonics Corp., 28 F.4th 956 (9th Cir. 2022). · cites it 3× “The panel held that the state law applicable here, Cal. Labor Code § 925 (b), which grants employees the option to void a forum-selection clause under a limited set of circumstances, determined the question of whether Waber’s contract contained a valid forum-selection clause.”

Ryze Claim Solutions LLC v. Superior Court of Contra Costa Cnty., 245 Cal. Rptr. 3d 575 (Cal. Ct. App. 5th 2019). · cites it 4× “" (Lab. Code, § 925, subd. (a).) The statute also expressly states: "This section shall apply to a contract entered into, modified or extended on or after January 1, 2017.”

C.H. Robinson Worldwide, Inc. v. Traffic Tech, Inc., 60 F.4th 1144 (8th Cir. 2023). · cites it 2× “Cal. Lab. Code § 925 (a)–(b). Of the five former employees, only Peacock began working for Traffic Tech and signed his employment contract after California’s anti- waiver statute took effect.”

Matter of Dentons US LLP v. Zhang, 2022 NY Slip Op 07498 (N.Y. App. Div. 2022). “irm three arbitral awards rendered by an emergency arbitrator under the authority of the International Institute for Conflict Prevention & Resolution (CPR), and denied respondent's cross motion to stay or dismiss this proceeding, unanimously affirmed, with costs, without…”

Nuvasive, Inc. v. Patrick Miles (Del. Ch. 2018). · cites it 7× “It has recognized that in the limited subset of cases where the inequality of bargaining strength of the 1 Cal. Lab. Code § 925 (e). 2 parties to an employment contract is buffered by the employee being represented by independent counsel, and where counsel participated in…”

Joubert v. Lienhard (N.D. Cal. 2020). · cites it 6× “Plaintiff responds that the choice- 5 of-law provision is invalid under California Labor Code section 925. Opp’n at 10–13.”

Ryze Claim Solutions LLC v. Superior Court (Cal. Ct. App. 2019). · cites it 5× “The trial court observed that forum selection clauses will not be enforced when contrary to California public policy and found that enforcing the forum selection clause would “go against the state’s public policy expressed in at least two statutes,” specifically citing Labor…”

LGCY Power v. Super. Ct. (Cal. Ct. App. 2022). · cites it 5× “-ooOoo- California Labor Code section 925 went into effect on January 1, 2017, and provides that employers cannot force an employee who resides and works primarily in California to agree, as a condition of employment, to: (1) litigate a claim arising in California in a forum…”

Zhang v. Super. Ct. (Cal. Ct. App. 2022). · cites it 5× “) The court concluded: “[The] Plaintiffs’ arguments regarding the scope of the arbitration agreement; the application of California Labor Code Section 925; and the application [of]California Labor Code Section 229 may well render the claims unarbitrable.”

LaCasse v. USANA Health Sciences, Inc. CA3 (Cal. Ct. App. 2023). · cites it 5× “he reply brief also argued that: (1) LaCasse accepted the terms of the Associate Agreement by her conduct; (2) the Associate Agreement incorporated the USANA Policies by reference; (3) the forum selection clauses in the Associate Agreement and USANA Policies were mandatory; (4)…”

Miller-Garcia v. Avani Media, LLC (N.D. Cal. 2020). · cites it 5× “Cal. Labor Code § 925 (a), (b). On that basis, Miller-Garcia filed a motion to dismiss 19 the action in the Tennessee court.”

Jurek v. Piller USA, Inc. (S.D. Cal. 2021). · cites it 5× “13 14 Cal. Lab. Code § 925 . Section 925 is not retroactive and applies “to a contract entered 15 into, modified, or extended on or after January 1, 2017.”

Belkorp AG, LLC v. Venture Prods., Inc. (N.D. Ohio 2026). · cites it 5× “He stated that he would exercise his right to void the forum-selection clause under California Labor Code section 925, which allows certain contracts with California employees to be “voidable by the employee” under specific conditions.”

Dopp v. Now Optics CA4/1 (Cal. Ct. App. 2024). · cites it 4× “Enacted in 2017, Labor Code section 925, subdivision (a) now states that an employer may not require a California employee to agree as a condition of employment to a provision that would either (1) require the employee to “adjudicate” claims arising in California outside of…”

McKellar v. Mithril Capital Mgmt. LLC (N.D. Cal. 2020). · cites it 4× “California Labor Code § 925 9 Although the Court agrees McKellar’s claims against Royan and Mithril Capital must be 10 compelled to arbitration, the question remains where that arbitration should proceed.”

Pierman v. Stryker Corp. (S.D. Cal. 2020). · cites it 4× “” Cal. Lab. Code § 925 (a). “Any provision of a contract that violates 26 |) subdivision (a) is voidable by the employee, and if a provision is rendered void at the 27 |\request of the employee, the matter shall be adjudicated in California and California law 28 || shall govern…”

Buchsbaum v. Digit. Intelligence Sys., LLC (S.D. Cal. 2020). · cites it 4× “) “In reaching a decision, the arbitrator shall apply the governing substantive law 8 applicable to the claims, causes of action, and defenses asserted by the parties as applicable 9 in the State of Virginia.”

Eller v. Automatic Data Processing, Inc. (S.D. Cal. 2023). · cites it 4× “1 The Court finds a likelihood 6 that (1) California Labor Code § 925 (“Section 925”) makes voidable the choice of law 7 provisions in the Agreements and (2) even if Section 925 did not apply, California law 8 applies under the choice of law default rules.”

C.H. Robinson Worldwide, Inc. v. Traffic Tech, Inc. (D. Minnesota 2021). · cites it 4× “California Labor Code § 925. With respect to Antobenedetto, Buckley, Dossey and Aguiniga, CHR argues that Minnesota law applies to the claims against them, as the Minnesota choice of law provision in their CPB Agreements are valid, and as a result, Minnesota law governs the…”

Patel v. SAP Am., Inc. (N.D. Cal. 2025). · cites it 4× “DISCUSSION 3 The parties’ dispute regarding transfer turns on whether the 2022 GIP forum selection 4 clause violates California Labor Code § 925 and is, as Plaintiff argues, “unreasonable” and 5 contravenes the public interest.”

Patel v. SAP Am., Inc. (E.D. Pa. 2025). · cites it 4× “DISCUSSION 3 The parties’ dispute regarding transfer turns on whether the 2022 GIP forum selection 4 clause violates California Labor Code § 925 and is, as Plaintiff argues, “unreasonable” and 5 contravenes the public interest.”

Grove v. Juul Labs, Inc. (Cal. Ct. App. 2022). · cites it 3× “” (Lab. Code, § 925, subd. (a).) A contract provision that violates section 925 is voidable by the employee, in which case the employee’s claim(s) shall be adjudicated in California under California law.”

Luis Montoya Jr. v. Ariba Inc. (C.D. Cal. 2023). · cites it 3× “Cal. Lab. Code § 925 (a). “Section 925 expresses California’s strong public policy against forum-selection clauses in employment agreements.”

Tyler Kem v. Strike Advisory, LLC (C.D. Cal. 2023). · cites it 3× “” Cal. Lab. Code §925 (a). Defendants argue that § 925 does not apply because it “requires a showing of fraud or deceit on behalf of the employer to take advantage of the employee via the forum selection clause, or that the acceptance of the .”

Yeomans v. World Fin. Grp. (N.D. Cal. 2019). · cites it 3× “at 22 (citing Cal. Labor Code §925 (c) (“a court may award an employee who is enforcing his 19 or her rights under this section reasonable attorney’s fees”)).”

TigerGraph, Inc. v. Peak (N.D. Cal. 2020). · cites it 3× “1 California Labor Code § 925 provides that California employers may not require 2 California employees to sign employment agreements that mandate a venue and choice 3 of law provision outside California and defendant asserts that this policy is analogous to 4 his situation…”

Chalmers v. DSSV, Inc. (N.D. Cal. 2023). · cites it 3× “29 at 3; Cal. Lab. Code § 925 (a). This 2 statute has no immediate bearing on this Plaintiff or the parties’ Agreement, since Plaintiff – the 3 “employee” – does not “primarily reside[]” or “work[]” in California.”

Broom v. Interact Commc'ns, Inc. (S.D. Cal. 2021). · cites it 3× “) 24 On November 6, 2020, Plaintiffs filed this complaint seeking a declaration that the 25 non-compete provisions in their employment contracts are invalid under California 26 Business and Professions Code § 16600 and for breaches of California Labor Code § 925 27 and Business…”

Tovar v. GC Servs. Ltd. P'ship (S.D. Cal. 2021). · cites it 3× “As discussed below, applying 26 Texas law would conflict with California Labor Code § 925, which evinces a fundamental California policy prohibiting employers from requiring California employees to agree to litigate in a different forum 27 as a prerequisite to employment.”

LifeVoxel.AI Inc. v. Mamillapalli (D. Conn. 2024). · cites it 3× “Defendant then raises several other arguments: (1) pursuant to California Labor Code § 925, the provision of the arbitration agreement requiring the arbitration to occur in Connecticut must be voided and is unlawful; (2) the claims brought against him in arbitration are beyond…”

Elevance Health, Inc. v. Mohan (S.D. Ind. 2023). · cites it 3× “Mohan had accepted a position as Senior Vice President of Medicare at Molina; (2) her start date was August 30, 2023; and (3) pursuant to California Labor Code section 925, Ms. Mohan was "exercising her rights .”

Pacelli v. Augustus Intelligence, Inc. (S.D.N.Y. 2020). · cites it 3× “Crump, arguing in the negative, invokes Cal. Lab. Code § 925 (hereinafter, “Section 925”), which provides that “[a]n employer shall not require an employee who primarily resides and works in California, as a condition of employment, to agree to a provision that would .”

Luis Montoya Jr. v. Ariba Inc. (E.D. Pa. 2023). · cites it 3× “Cal. Lab. Code § 925 (a). “Section 925 expresses California’s strong public policy against forum-selection clauses in employment agreements.”

Johnathon Ervin v. Amazon.com Servs., LLC (C.D. Cal. 2025). · cites it 3× “California Labor Code Section 925 14 Similarly, the Court does not reach Ervin’s challenge that the DSP Agreement is 15 unenforceable under California Labor Code section 925.”

Kashmolah (N.D. Ohio 2025). · cites it 3× “Kashmolah also argues he declared the Ohio choice of law provision “void” under California Labor Code § 925. (Doc. 21 at 242-43.”

Midwest Motor Supply Co. v. Super. Ct. (Cal. Ct. App. 2020). · cites it 2×

Denise Zapata v. Cambridge Inv. Rsch., Inc. (C.D. Cal. 2022). · cites it 2×

Stephen D. Healy v. Qognify, Inc. (C.D. Cal. 2020). · cites it 2×

Gold Coast Search Partners LLC v. Career Partners, Inc. (N.D. Cal. 2019). · cites it 2×

Yeomans v. World Fin. Grp. (N.D. Cal. 2020). · cites it 2×

Norris v. Aon PLC (N.D. Cal. 2021). · cites it 2×

Ruff v. Wilson Logistics, Inc. (N.D. Cal. 2022). · cites it 2×

O'Connell v. Celonis, Inc. (N.D. Cal. 2022). · cites it 2×

Franey v. Am. Battery Solutions Inc. (N.D. Cal. 2022). · cites it 2×

Blair v. INFORM Software Corp. (N.D. Cal. 2023). · cites it 2×

Bazine v. Kelly Servs. Global, LLC (N.D. Cal. 2023). · cites it 2×

Cherry Creek Mortg. LLC v. Jarboe (D. Colo. 2022). · cites it 2×

Ronnoco Coffee LLC v. Castgna (E.D. Mo. 2021). · cites it 2×

Pinedo v. A Place For Mom (N.D. Cal. 2024). · cites it 2×

Vashisht-Rota v. Utah Attorney Gen. (S.D. Cal. 2024). · cites it 2×

Graciela Tanious v. Wells Fargo Advisors Fin. Network, LLC (C.D. Cal. 2024). · cites it 2×

Stevens & Co., LLC v. Espat (S.D.N.Y. 2025). · cites it 2×

Arden Reneau v. Penske Truck Leasing Co., L.P. (C.D. Cal. 2025). · cites it 2× “WarnerMedia Direct 23 24 1 California Labor Code § 925(a) provides that an employer “shall not require an employee who primarily resides and works in California, as a condition of employment, to agree to a 25 provision that would” require the adjudication of a claim arising in…”

Arden Reneau v. Penske Truck Leasing Co., L.P. (E.D. Pa. 2025). · cites it 2× “WarnerMedia Direct 23 24 1 California Labor Code § 925(a) provides that an employer “shall not require an employee who primarily resides and works in California, as a condition of employment, to agree to a 25 provision that would” require the adjudication of a claim arising in…”

C.H. Robinson Worldwide, Inc. v. Traffic Tech, Inc. (8th Cir. 2025). · cites it 2× “Code § 1717 (a) (providing in an action arising under a contract with attorney fee-shifting provisions that any prevailing party in the action “shall be entitled to reasonable attorney[] fees”); Cal. Labor Code § 925 (a)(2) and (c) (providing that “a court may award” attorney…”

Go (N.D. Cal. 2026). · cites it 2× “Code § 925 by requiring the application of New York law, subjects 16 employees to costs that are unique to arbitration, limits statutory attorney’s fees or costs, and waives 17 rights to recover statutory costs, seek public relief, and bring representative PAGA claims (because…”

Sellers v. World Fin. Grp. CA4/1 (Cal. Ct. App. 2022).

Casement v. Soliant Health, Inc. (E.D. Cal. 2020).

McGechie v. Atomos Ltd. (E.D. Cal. 2024).

Walters v. Famous Transports, Inc. (N.D. Cal. 2020).

Fleming v. Matco Tools Corp. (N.D. Cal. 2020). “26 2 Fleming alternatively argues that California Labor Code section 925(a) voids Matco’s choice of 27 law clause such that California law, not Ohio law, should apply.”

Norris v. Aon PLC (N.D. Cal. 2021).

Callahan v. Paychex North Am. Inc. (N.D. Cal. 2022).

Stability Solutions, LLC v. Medacta USA, Inc. (N.D. Cal. 2023).

Abeyta v. DMCG, Inc. (N.D. Cal. 2023).

Aguila v. Becton & Dickinson (N.D. Cal. 2023).

Peters v. Guaranteed Rate, Inc. (N.D. Cal. 2024).

Dexcom, Inc. v. Medtronic, Inc. (S.D. Cal. 2021).

Barker v. Northrop Grumman Sys. Corp. (S.D. Cal. 2022).

Medcor, Inc. v. Garcia (N.D. Ill. 2022).

Jefferies LLC v. Gegeheimer (S.D.N.Y. 2020).

Perry v. Floss Bar, Inc. (S.D.N.Y. 2021).

Tropic Tech., Inc. v. Vendr, Inc. (S.D.N.Y. 2023).

Stability Solutions, LLC v. Medacta USA, Inc. (M.D. Tenn. 2023).

Bonetti v. TriStruX LLC (N.D. Cal. 2024).

C.H. Robinson Worldwide, Inc. v. Traffic Tech, Inc. (D. Minnesota 2024).

Perimeter Solutions LP v. Davis (E.D. Mo. 2024).

Howell Mgmt. Servs. v. Vashisht-Rota CA4/1 (Cal. Ct. App. 2025).

Belkorp AG, LLC v. Venture Prods., Inc. (N.D. Ohio 2025).

Belkorp AG, LLC v. Venture Prods., Inc. (E.D. Cal. 2025).

Roberts v. IFS Topco, LLC (S.D. Cal. 2025).

Peters v. Guaranteed Rate, Inc. (9th Cir. 2025).

EpicentRx v. Super. Ct. (Cal. 2025).

Wonacott v. Thor Motor Coach CA3 (Cal. Ct. App. 2025).

C.H. Robinson Worldwide, Inc. v. Traffic Tech, Inc., James Antobenedetto, Spencer Buckley, Wade Dossey, Brian Peacock, & Dario Aguíñiga (D. Minnesota 2025).

Wesley Hunter v. Pre-Paid Legal Servs., Inc. (N.D. Cal. 2025).

Nash (E.D. Cal. 2025).

BayWa r.e. Wind v. RSG Underwriting Managers CA2/2 (Cal. Ct. App. 2026).

— Cal. Labor Code § 925(a) — 7 cases

Tyler Kem v. Strike Advisory, LLC (C.D. Cal. 2023). “” Cal. Lab. Code §925 (a). Defendants argue that § 925 does not apply because it “requires a showing of fraud or deceit on behalf of the employer to take advantage of the employee via the forum selection clause, or that the acceptance of the .”

Yeomans v. World Fin. Grp. (N.D. Cal. 2019). “at 22 (citing Cal. Labor Code §925 (c) (“a court may award an employee who is enforcing his 19 or her rights under this section reasonable attorney’s fees”)).”

Chalmers v. DSSV, Inc. (N.D. Cal. 2023). “29 at 3; Cal. Lab. Code § 925 (a). This 2 statute has no immediate bearing on this Plaintiff or the parties’ Agreement, since Plaintiff – the 3 “employee” – does not “primarily reside[]” or “work[]” in California.”

Eller v. Automatic Data Processing, Inc. (S.D. Cal. 2023). “1 The Court finds a likelihood 6 that (1) California Labor Code § 925 (“Section 925”) makes voidable the choice of law 7 provisions in the Agreements and (2) even if Section 925 did not apply, California law 8 applies under the choice of law default rules.”

Arden Reneau v. Penske Truck Leasing Co., L.P. (C.D. Cal. 2025). “WarnerMedia Direct 23 24 1 California Labor Code § 925(a) provides that an employer “shall not require an employee who primarily resides and works in California, as a condition of employment, to agree to a 25 provision that would” require the adjudication of a claim arising in…”

Arden Reneau v. Penske Truck Leasing Co., L.P. (E.D. Pa. 2025). “WarnerMedia Direct 23 24 1 California Labor Code § 925(a) provides that an employer “shall not require an employee who primarily resides and works in California, as a condition of employment, to agree to a 25 provision that would” require the adjudication of a claim arising in…”

— Cal. Labor Code § 925(b) — 2 cases

— Cal. Labor Code § 925(c) — 1 case

Jurek v. Piller USA, Inc. (S.D. Cal. 2021). “13 14 Cal. Lab. Code § 925 . Section 925 is not retroactive and applies “to a contract entered 15 into, modified, or extended on or after January 1, 2017.”

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