Michael Scantland v. Jeffry Knight, Inc.
721 F.3d 1308
11th Cir.2013Background
- Plaintiffs are current/former technicians who installed/repaired BHN services for Knight in Florida and bring a collective FLSA claim for overtime/minimum wage protections.
- District court granted summary judgment that plaintiffs were independent contractors, not employees, under the FLSA.
- Court reverses, holding the district court erred in treating plaintiffs as independent contractors after applying the economic reality test.
- Court adopts a six-factor framework to evaluate economic dependence, emphasizing overall dependence rather than any single factor.
- Knight’s control—scheduling, billing codes, route assignments, supervisions, training, and discipline through chargebacks—supports an employee status determination, while investments and certain skills weigh less toward contractor status.
- Court remands for further proceedings consistent with its economic-dependence ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the six-factor economic-reality test supports employee status. | Plaintiffs show dependence on Knight. | Knight contends independent contractor status. | Yes; factors favor employee status. |
| Whether Knight’s control over scheduling, pay codes, and discipline demonstrates economic dependence. | Control indicates dependence and employee relationship. | Control is routine business practice, not full control. | Yes, control supports employee status. |
| Whether permanency and exclusivity weigh toward employee status. | Long tenure and exclusivity show dependence. | Exclusivity and duration are not determinative. | Yes, favors employee status. |
| Whether investment in equipment and special skill negate contractor status. | Some investments and skills indicate independence. | Investments/skills are insufficient to show independence. | Weighs weakly toward independent contractor or neutral. |
Key Cases Cited
- Rutherford Food Corp. v. McComb, 331 U.S. 722 (1947) (overtly broad FLSA protections rely on economic reality of dependence)
- Bartels v. Birmingham, 332 U.S. 126 (1947) (economic reality test for employment based on dependence)
- Goldberg v. Whitaker House Coop., Inc., 366 U.S. 28 (1961) (economic reality approach over labels or contracts)
- Aimable v. Long & Scott Farms, Inc., 20 F.3d 434 (11th Cir. 1994) (economic-dependence framework for employment status)
- Usery v. Pilgrim Equip. Co., 527 F.2d 1308 (5th Cir. 1976) (multifactor approach to determine employee vs independent contractor)