California, United States of America
The following excerpt is from Strategic Concepts, LLC v. Beverly Hills Unified Sch. Dist., 23 Cal.App.5th 163, 232 Cal.Rptr.3d 579 (Cal. App. 2018):
Division 1 of this court reversed the conviction in People v. Christiansen (2013) 216 Cal.App.4th 1181, 157 Cal.Rptr.3d 451. The court reasoned that for the purposes of criminal law, section 1090 did not apply to independent contractors. The court declined to decide the scope of section 1090 as applied to civil actions.
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