Layton v. DHL Express (USA), Inc., No. 11-12532 (11th Cir. 2012)
Annotate this CasePetitioner Leandre Layton, on behalf of himself and the similarly-situated members of his conditionally-certified class (collectively, "Drivers"), appealed the district court's grant of summary judgment in favor of DHL Express, Inc. ("DHL") on his claims under the Fair Labor Standards Act ("FLSA"). DHL contracted with Sky Land Express, Inc. to manage local parcel deliveries. Petitioner worked on DHL routes for Sky Land. Petitioner filed his collective action for unpaid overtime, naming DHL, Sky Land and Gary Littlefield (owner and president of Sky Land) as his joint employers and defendants to the suit. DHL moved for summary judgment on the ground that it was not the drivers' employer. The district court granted DHL's motion: "DHL did everything it could possibly do to relate to Sky Land only as an "independent contractor[."] The contract with Sky Land allowed DHL to exercise only the minimal supervision necessary to monitor compliance with the contract. The undisputed facts lead to the conclusion that if plaintiffs were employed by anybody, they were employed by Sky Land, the entity that they ostentatiously dismissed as a defendant, for reasons this court can only guess at. DHL was not an employer, much less a joint employer." After a thorough examination of the realities of the economic relationship between Drivers and DHL, the Eleventh Circuit affirmed on the grounds that DHL was not a joint employer of the Drivers.
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