Leandre Layton v. DHL Express, Inc.
686 F.3d 1172
| 11th Cir. | 2012Background
- Layton, on behalf of a conditionally-certified FLSA collective, sues DHL Express and Sky Land Express for unpaid overtime in Alabama.
- DHL contracted Sky Land to supply delivery drivers; Sky Land employed the Drivers and owned their vans, while DHL owned warehouses and most equipment.
- A Cartage Agreement labeled Sky Land as an independent contractor; DHL performed only minimal supervision and dictated broad objectives, not daily tasks.
- Drivers’ daily routine involved loading, sorting, and delivering packages with data from DHL-provided scanners transmitted at day’s end.
- The district court granted summary judgment for DHL, finding no joint-employer relationship; Layton appeals.
- The Eleventh Circuit reviews de novo, focusing on the economic realities and applying Aimable’s eight-factor test to determine joint employment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether DHL is a joint employer under the FLSA. | Layton asserts DHL jointly employs Drivers via contract and control. | DHL contends it only contracted Sky Land; no joint control or economic dependence exists. | No joint-employer relationship; DHL not an employer. |
| Impact of Aimable eight-factor test on DHL's status. | Eight factors show economic dependence on DHL. | Factors show Sky Land’s independent control and lack of DHL involvement. | Totality of circumstances show lack of economic dependence on DHL. |
| Relevance of ownership of facilities and equipment to joint employment. | Ownership may indicate dependency and control. | Both Sky Land and DHL invest; ownership does not prove joint employment. | Ownership factor does not establish joint employment. |
| What role do payroll and wage payment arrangements play in joint employment. | DHL’s involvement in payroll could indicate control. | Sky Land handles payroll; DHL has no payroll control. | Payroll arrangement weighs against joint employment. |
Key Cases Cited
- Aimable v. Long & Scott Farms, 20 F.3d 434 (11th Cir. 1994) (eight-factor test for joint employment under AWPA/FLSA)
- Antenor v. D & S Farms, 88 F.3d 925 (11th Cir. 1996) (economic-dependency framework; eight-factor guidance)
- Charles v. Burton, 169 F.3d 1322 (11th Cir. 1999) (AWPA joint-employment seven-factor test (persuasive authority))
- Martinez-Mendoza v. Champion Int'l Corp., 340 F.3d 1200 (11th Cir. 2003) (limited direct oversight as insufficient supervision for joint employment)
- Rutherford Food Corp. v. McComb, 331 U.S. 722 (1947) (production-line integration as an indicator of employment)
- Vector Products, Inc. v. Hartford Fire Ins. Co., 397 F.3d 1316 (11th Cir. 2005) (de novo review of summary judgment grounds)