Mark Fochtman v. Hendren Plastics, Inc., No. 20-2061 (8th Cir. 2022)
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In this class action, participants in a drug and alcohol recovery program alleged the program assigned them to work for defendant Hendren, a private company that paid the program for their services. Plaintiffs alleged the defendants failed to pay them the required minimum wage. The district court held that plaintiffs were employees and granted them relief. Defendant appealed.
On appeal, the Eighth Circuit reversed, finding that the fact that the work Plaintiffs performed as participants in a court-ordered recovery program benefited Hendren did not make the program participants employees of either the program or Hendren. Thus, because Plaintiffs were not employees, they were not entitled to relief.
Court Description: [Colloton, Author, with Loken and Benton, Circuit Judges] Civil case - Arkansas Minimum Wage Act. In this class action, participants in a drug and alcohol recovery program alleged the program assigned them to work for defendant Hendren, a private company which paid the program for their services; plaintiffs alleged the defendants failed to pay them the required minimum wage; the district court concluded the plaintiffs were employees and granted them relief. Held: the state drug court judgments assigning the plaintiffs to the program did not present a Rooker-Feldman issue, and the district court had jurisdiction over the suit under the Class Action Fairness Act; the plaintiffs in the suit were the primary benefits of the unusual work and payment arrangements between the program and Hendren in that it allowed them to avoid adjudication in the criminal justice system, and the fact that the work they performed as participants in a court-ordered recovery program also benefited Hendren did not make the program participants employees of either the program or Hendren; as the plaintiffs were not employees, the district court judgment is reversed.
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