Hall v. DIRECTV, LLC, No. 15-1857 (4th Cir. 2017)Annotate this Case
Plaintiffs, two groups of satellite television technicians, filed suit alleging that defendants, through a web of agreements with various affiliated and unaffiliated service providers, are jointly and severally liable for violations of the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq. The district court dismissed the pleadings because plaintiffs failed to adequately allege that DIRECTV and DirectSat jointly employed plaintiffs. The court concluded that the district court relied on out-of-circuit authority that the court has since rejected as unduly restrictive in light of the broad reach of the FLSA. The court concluded that, under the appropriate legal standards, plaintiffs have alleged sufficient facts to make out a plausible claim that defendants jointly employed them as DIRECTV technicians; defendants may be held jointly and severally liable in the event that plaintiffs performed uncompensated overtime work for defendants during plaintiffs’ respective periods of employment; and the court reversed the dismissal of plaintiffs' FLSA and Maryland state-law claims against defendants because they have sufficiently pleaded that DIRECTV jointly employed them as satellite technicians, and that they are owed some amount of unpaid compensation. The court remanded for further proceedings.