The Truth About Hoby Buchanan Legal Cases: What Actually Happened (2022 California Labor Commissioner Decision)

There is no active “Hoby Buchanan lawsuit” in 2024 or 2025. The only verified legal proceeding involving Hoby Buchanan occurred in a January 2022 California Labor Commissioner decision where he was mentioned as a subject—not as a plaintiff or defendant. Adult film performer Cameron Baggott (stage name Arietta Adams) alleged her talent agency Direct Models Inc. sent her into an unsafe working environment with Buchanan in June 2019. The Labor Commissioner ruled Baggott failed to prove her agency violated safety standards regarding the Buchanan shoot.

What Is the Hoby Buchanan Case About?

The case involves Cameron Baggott, an adult film performer who filed complaints against her talent agency Direct Models Inc. and its owner Derek Hay in 2020-2021. Hoby Buchanan, an adult film director and performer, was mentioned in the case because Baggott alleged her agency failed to properly vet safety conditions before booking her for a shoot with him on June 18, 2019.

Key facts:

Case numbers: TAC-52764 and TAC-52829
Decision date: January 19, 2022
Court: California Department of Industrial Relations, Division of Labor Standards Enforcement
Buchanan’s role: Subject of safety allegations, not a party to the case
Location of shoot: Airbnb in an undisclosed location
Type of content: Point-of-view “gonzo” adult film shoot

What Were the Specific Allegations in the Case?

Baggott filed cross-petition TAC-52829 alleging Direct Models violated the California Talent Agencies Act by sending her into unsafe working conditions without reasonable inquiry. Her complaints included several incidents, with the Hoby Buchanan shoot being one of them.

Allegations about the Buchanan shoot:

Buchanan and Baggott were the only two people present at the filming
The shoot was filmed on an iPad rather than professional equipment
The location was an Airbnb rental, not a professional studio
Baggott testified Buchanan repeatedly did not stop when she expressed she was in pain and asked him to stop
Her agent Christopher Fleming did not verify safety protocols, establish safe words would be used, or confirm crew presence before booking

What Baggott claimed her agency should have done:

Ask about professionalism of the shoot setup
Confirm who would be present on set
Verify safe words would be established
Check filming equipment quality
Inspect the location

What Was Hoby Buchanan’s Background in This Case?

According to the Labor Commissioner’s decision, all parties agreed Hoby Buchanan is an adult entertainment director and performer who films “rougher” adult entertainment scenes. Agent Christopher Fleming testified he performed due diligence before offering the shoot to Baggott.

Fleming’s due diligence included:

Researching Buchanan’s social media pages
Reviewing his websites and content
Examining Buchanan’s shoots with other successful adult entertainment talent
Checking his “paid membership website”
Reviewing his “well-established Porn Hub channel”

Fleming did not:

Visit the set location
Establish that safe words would be used
Confirm whether the set was a rental or professional studio
Ask about filming equipment
Ensure more than two people would be on set

What Did Cameron Baggott Say About the Shoot?

Baggott provided testimony about her experience during the June 18, 2019 shoot with Buchanan. She had previously performed in similar “rougher” genre shoots and had expressed interest in working with Buchanan when Fleming first asked her in April 2019.

Baggott’s immediate reaction after the shoot: She messaged Fleming stating “everything went well[;] he[‘s] just like super amateur,” noting “it felt like a content trade.” She stated she would not want to do rougher anal scenes with Buchanan in the future. Fleming responded that “the content is quite amateurish in production which you can see on his site but he seems like a professional and nice guy.” Baggott agreed Buchanan “is r[ea]lly nice tho[ugh]” and said she would shoot another scene of a different type with him in the future. Baggott affirmed in her testimony that Buchanan was nice.

Her later testimony at the hearing: Baggott testified credibly that unlike other shoots she had performed with similar content, Buchanan repeatedly did not stop when she told him she was in pain and asked him to stop.

What Are the Most Recent Legal Developments or Court Rulings?

The California Labor Commissioner issued the final determination on January 19, 2022. This is the most recent and only legal ruling involving Hoby Buchanan.

The Labor Commissioner’s ruling on the Buchanan allegations:

The Commissioner ruled Baggott failed to meet her burden of proof to show Fleming and Direct Models acted outside their obligation to conduct reasonable inquiry into the safety of the work environment.

Why Baggott’s claim failed:

Baggott did not present other witnesses from the adult entertainment industry to testify on industry standards for due diligence
She provided no specific evidence of Buchanan’s prior reputation that Fleming should have known about
Fleming presented an explanation that reviewing content type, obtaining talent consent, and examining other talent the director worked with was sufficient due diligence
The Labor Commissioner found both explanations “equally plausible”
Without additional evidence, the burden of proof was not met

The Commissioner’s exact language: “While Baggott’s contention is plausible that Fleming should have conducted additional diligence, Fleming presents an equally plausible explanation that reviewing the type of content, obtaining consent from the talent, and examining other talent with whom the director has worked was sufficient due diligence to constitute a reasonable inquiry. Without more, the evidence is in equipoise. Because it was Baggott’s burden to prove that Fleming violated his duty, Baggott’s claim fails.”

Who Filed the Case and Who Are the Parties Involved?

Plaintiffs:

Cameron Baggott (also known as Arietta Adams and Jane Doe) – Adult film performer
Represented by attorney Joseph Salama

Defendants:

Direct Models Inc. (dba LA Direct Models) – California talent agency specializing in adult entertainment representation
Derek Hay – Owner and President of Direct Models
Represented by attorney Karen Tynan

Key witnesses:

Christopher Fleming – Talent agent at Direct Models who directly handled Baggott’s representation
Hoby Buchanan – Adult film director/performer (subject of allegations, not a party)

Case background: Baggott signed a two-year exclusive representation agreement with Direct Models on February 15, 2019. She was represented primarily by Derek Hay and Christopher Fleming. Baggott lived in Florida but traveled for work. Her last shoot where she paid commission to Direct Models was January 29, 2020.

What Was the Defendant’s Response?

Direct Models and Derek Hay denied violating their duty to protect Baggott’s health and safety. They argued their agent Christopher Fleming performed adequate due diligence before booking the Buchanan shoot.

Direct Models’ defense regarding the Buchanan shoot:

Fleming checked Baggott’s willingness to perform “rougher” content before offering the job
Fleming researched Buchanan’s work, social media, websites, and content before booking
Fleming saw Buchanan had worked with other successful adult entertainment talent
Many adult film shoots occur in rental locations with minimal crew for point-of-view content
Agents do not generally check film equipment or safe words ahead of time for such shoots
Two-person shoots are not unusual in the industry

Industry standards dispute: Direct Models and Hay testified that many shoots are performed in rentals, two-person shoots are common, and agents do not generally verify film equipment or safe words ahead of time. Baggott testified it is not industry practice for an agent to send a client to a producer of “rougher” entertainment with whom the agency has never worked without asking questions about professionalism, who would be on set, or whether safe words existed.

Who Is Affected by This Case?

Cameron Baggott: The Labor Commissioner ruled against her safety claims regarding Buchanan but found Direct Models violated other provisions of the Talent Agencies Act. She was awarded $5,428.15 in disgorgement of unlawful fees unrelated to the Buchanan shoot.

Direct Models Inc.: Ordered to pay Baggott $5,428.15 for charging fees not disclosed in their Schedule of Fees (Nightmoves flight fee, Stoney Curtis kill fee, and booking fees). The company was not found liable for safety violations regarding the Buchanan shoot.

Derek Hay: Not held personally liable for the unlawful fees. The Commissioner found Baggott failed to prove Hay engaged in individual tortious conduct warranting personal liability.

Adult entertainment industry: The case clarified standards for talent agency due diligence when booking performers for shoots, particularly regarding “rougher” content and new directors.

What Damages or Relief Were Sought?

Baggott sought disgorgement of all commissions paid to Direct Models, claiming the agency violated the California Talent Agencies Act by:

Sending her into unsafe working conditions without reasonable inquiry
Charging unlawful fees not disclosed in the Schedule of Fees
Failing to properly vet producers and directors

Direct Models sought unpaid commissions from Baggott for shoots she performed in late 2020 and early 2021, claiming she violated their two-year contract by not paying the required 15% commission.

What Is the Current Status of the Case?

The case is resolved. The California Labor Commissioner issued the final determination on January 19, 2022. There are no current appeals or ongoing litigation involving Hoby Buchanan.

Final rulings:

Direct Models’ claim for unpaid commissions: DENIED (contract was no longer in effect)
Baggott’s safety claims regarding Hoby Buchanan: DENIED (failed to meet burden of proof)
Baggott’s claims regarding unlawful fees: PARTIALLY GRANTED
Total award to Baggott: $5,428.15 plus interest

Breakdown of awarded fees:

Nightmoves flight fee: $150 + $33.12 interest = $183.12
Stoney Curtis kill fee: $330 + $71.61 interest = $401.61
Booking fees (37 bookings after May 7, 2019): $3,700 + $1,143.42 interest = $4,843.42

The Commissioner also ordered Baggott to file a supplemental brief regarding attorney’s fees and costs within two weeks of the January 19, 2022 decision.

What Are the Potential Outcomes?

The case is already concluded. The January 19, 2022 determination represents the final outcome. Neither party has filed appeals or new litigation since that date.

What the ruling means:

Talent agencies must disclose all fees in their Schedule of Fees filed with the Labor Commissioner
Agencies cannot charge “backdoor” fees to studios that effectively increase compensation above disclosed rates
The burden of proof for safety violations requires substantial evidence of industry standards and the director’s reputation
Talent must provide witnesses or documentation to prove agency failed to meet due diligence standards

What Similar Lawsuits or Legal Precedents Exist?

The Labor Commissioner referenced two previous cases involving Direct Models that found the agency violated safety duties:

Szarko v. Direct Models, Inc. (TAC 50639, October 2018): The Commissioner established that Labor Code section 1700.33 implies into every talent agency contract the duty to “engage in reasonable inquiry to determine whether an artist’s health, safety or welfare would be adversely affected by being sent to a job they are attempting to procure for the artist.”

Jane Does v. Hay (TAC-52663, June 2020): Another case where the Labor Commissioner found Direct Models violated safety duties by referring talent into unsafe situations.

Important distinction in Baggott’s case: The Commissioner noted that while previous cases found Direct Models liable for safety violations, Baggott’s attorney explicitly waived the right to argue preclusion or estoppel and did not introduce evidence or sworn testimony from those previous hearings. The Commissioner emphasized: “This decision does not contradict the Labor Commissioner’s earlier factual findings in specific cases and does not conclude that Hay definitively did not send Baggott (or other talent) into unsafe situations. It simply holds that Baggott failed to meet her burden.”

What Should Affected Parties or Witnesses Do?

For adult entertainment performers:

Review your talent agency contract and Schedule of Fees carefully
Verify all fees your agency charges match what’s disclosed in the Schedule of Fees filed with the California Labor Commissioner
Document any safety concerns immediately after shoots
Preserve text messages, emails, and communications with your agent
If you feel your agency sent you into unsafe conditions, gather evidence of industry standards and the producer’s reputation
Consider consulting with an attorney who specializes in entertainment law or labor law

For talent agencies:

File complete Schedule of Fees with the Labor Commissioner listing all fees you charge to talent OR studios
Conduct documented due diligence before booking talent with new directors
Keep records of safety inquiries made before bookings
Do not charge any fees not disclosed in your filed Schedule of Fees
Understand that “industry standard” fees still require disclosure

Rights under California law: California Labor Code section 1700.33 provides that “No talent agency shall send or cause to be sent, any artist to any place where the health, safety, or welfare of the artist could be adversely affected, the character of which place the talent agency could have ascertained upon reasonable inquiry.” Performers who believe their agency violated this duty can file a Petition to Determine Controversy with the California Labor Commissioner within one year of the alleged violation.

Why Is There Confusion About a “Hoby Buchanan Lawsuit”?

No lawsuit exists against or by Hoby Buchanan. The confusion stems from:

Buchanan being mentioned prominently in the 2022 Labor Commissioner decision
Online discussions of the case sometimes referring to it as involving Buchanan
The serious nature of Baggott’s testimony about her experience during the shoot
Searches for “Hoby Buchanan lawsuit” incorrectly suggesting he is a party to litigation

What actually happened: Buchanan was a third-party director who worked with Baggott in June 2019. The legal dispute was between Baggott and her talent agency Direct Models. Buchanan was neither sued nor accused of criminal conduct in this proceeding. The case examined whether Direct Models failed in its duty to properly vet working conditions before sending Baggott to work with Buchanan.

Frequently Asked Questions

Is Hoby Buchanan currently being sued?

No. There is no active lawsuit involving Hoby Buchanan as of December 2024. He was mentioned in a 2022 California Labor Commissioner case but was not a party to that proceeding.

Did Hoby Buchanan face criminal charges?

No criminal charges against Hoby Buchanan are mentioned in the 2022 Labor Commissioner decision or in any verified public records. The case was a civil labor dispute between Cameron Baggott and her talent agency.

What was the final outcome of the 2022 case?

Cameron Baggott’s safety claims regarding the Hoby Buchanan shoot were denied because she failed to meet her burden of proof. However, she won $5,428.15 in disgorgement of unlawful fees Direct Models charged her for unrelated issues. Direct Models’ claim for unpaid commissions was also denied.

When did the Hoby Buchanan shoot take place?

June 18, 2019. Cameron Baggott and Hoby Buchanan filmed a point-of-view “gonzo” adult scene at an Airbnb location. The shoot was filmed on an iPad with only the two of them present.

Can performers file complaints against talent agencies for safety violations?

Yes. California Labor Code section 1700.33 protects performers. They can file a Petition to Determine Controversy with the California Labor Commissioner within one year of an alleged violation. However, performers must provide substantial evidence that the agency failed to conduct reasonable inquiry into safety conditions.

What is “reasonable inquiry” for talent agencies?

The 2022 decision clarified this is fact-specific and depends on industry standards. For the Buchanan case, the Commissioner found checking the director’s content, social media, websites, other talent he’d worked with, and obtaining the performer’s consent could constitute reasonable inquiry. However, the Commissioner noted more diligence might be needed for “rougher” content with new directors the agency has never worked with before.

Are there other cases against Direct Models or Derek Hay?

Yes. The 2022 decision referenced two previous Labor Commissioner cases (Szarko v. Direct Models in October 2018 and Jane Does v. Hay in June 2020) where Direct Models was found liable for safety violations. Derek Hay also faced criminal charges unrelated to the Baggott case—Baggott testified she no longer wanted representation because “Mr. Hay was getting charged and arrested for pandering and all that criminal stuff going on.”

Disclaimer: This article is for informational purposes only and does not constitute legal advice. Information is based on the January 19, 2022 California Labor Commissioner Determination of Controversy (Case Nos. TAC-52764; TAC-52829). If you need legal assistance regarding talent agency disputes or workplace safety in the entertainment industry, consult with a qualified attorney licensed in your jurisdiction.

Last Updated: December 21, 2024

Sources:

California Department of Industrial Relations, Division of Labor Standards Enforcement, “Determination of Controversy: Direct Models Inc. v. Cameron Baggott,” Case Nos. TAC-52764; TAC-52829, issued January 19, 2022
California Labor Code sections 1700.2, 1700.24, 1700.33, 1700.44
California Code of Regulations, Title 8, section 12001

About the Author

Sarah Klein, JD, is a licensed attorney and legal content strategist with over 12 years of experience across civil, criminal, family, and regulatory law. At All About Lawyer, she covers a wide range of legal topics — from high-profile lawsuits and courtroom stories to state traffic laws and everyday legal questions — all with a focus on accuracy, clarity, and public understanding.
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