Munoz-Gonzalez v. D.L.C. Limousine Serv., Inc.
904 F.3d 208
2d Cir.2018Background
- DLC (D.L.C. Limousine Service, d/b/a LSW) operates a chauffeured car service in Westchester County with cars, SUVs, vans; drivers are dispatched centrally and most trips are local, many from the county airport.
- DLC does not use meters or rooftop TAXI signs; drivers wear uniforms and many passengers prepay; DLC had small recurring contracts (hotel, PepsiCo) amounting to <5% of business.
- Munoz-Gonzalez and other former drivers sued for unpaid overtime under the FLSA; DLC claimed the § 13(b)(17) taxicab exemption.
- The district court granted summary judgment for DLC; plaintiffs appealed, challenging the meaning of “taxicab” and relying on the DOL Field Operations Handbook.
- The Second Circuit interpreted “taxicab” by reference to contemporaneous dictionaries, statutory usage, and case law, articulated a three-factor test, and affirmed summary judgment for DLC.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Meaning of “taxicab” for § 13(b)(17) | Munoz-Gonzalez: term should exclude DLC’s chauffeured service; rely on Handbook distinctions (e.g., airport limousine). | DLC: its vehicles meet ordinary meaning of taxicab: passenger vehicles for hire without fixed routes/schedules. | Court: "taxicab" = (1) chauffeured passenger vehicle; (2) for hire by the general public; (3) no fixed schedule/route/termini — DLC meets all three. |
| Weight of DOL Field Operations Handbook | Handbook distinguishes airport limousine and taxicab; plaintiff urges deference to its guidance. | DLC: Handbook is nonbinding and inconsistent parts are not persuasive. | Court: Handbook is persuasive only to the extent it aligns with statutory text; declined to defer where inconsistent. |
| Effect of recurring contracts / airport trips | Plaintiff: recurrent contracts and majority airport-origin trips show DLC is an "airport limousine service," not a taxicab. | DLC: small share of recurrent contracts (<5%) and airport-origin trips do not change availability to public or lack of fixed routes. | Court: Contracts <5% irrelevant; "airport limousine" means shuttle on fixed route; DLC is not such a service. |
| Relevance of dispatch control, vehicle appearance, marketing | Plaintiff: centralized dispatch, lack of taxi meters/signs, uniforms, and luxury marketing show DLC is not a taxicab business. | DLC: these factors concern marketing or employment structure, not the statutory definition of "taxicab." | Court: These attributes are not dispositive; they do not defeat the taxicab exemption. |
Key Cases Cited
- Encino Motorcars, LLC v. Navarro, 138 S. Ct. 1134 (Sup. Ct. 2018) (FLSA exemptions receive a fair, not narrow, interpretation)
- Kingdomware Techs., Inc. v. United States, 136 S. Ct. 1969 (Sup. Ct. 2016) (start statutory interpretation with text; stop if unambiguous)
- Ramos v. Baldor Specialty Foods, Inc., 687 F.3d 554 (2d Cir. 2012) (standard of review for summary judgment)
- Cariani v. D.L.C. Limousine Serv., Inc., 363 F. Supp. 2d 637 (S.D.N.Y. 2005) (district court previously held DLC qualifies for taxicab exemption)
- Airlines Transp. v. Tobin, 198 F.2d 249 (4th Cir. 1952) (taxicabs operate without fixed routes or schedules; contrasted with airport shuttles)