Chapman v. Yellow Cab Cooperative, No. 17-1758 (7th Cir. 2017)Annotate this Case
Edwards owns a taxicab in Milwaukee and gets referrals from Yellow Cab. Edwards leased the cab to Giri, who subleased some of the time to Chapman so that the cab could be in service much of the day. Chapman received fares and tips, paid rent to Giri, and kept the difference; he did not pay or receive anything from Yellow Cab. Chapman argued, in his suit under the Fair Labor Standards Act that he was a Yellow Cab “employee” and that, after he complained about not receiving the minimum wage, Mohamed, Yellow Cab's President, told Giri that Chapman was “fired” (would not be dispatched to passengers calling Yellow Cab). Giri then terminated the sublease. Chapman argued that Mohamed’s action violated the Act’s anti-retaliation clause, 29 U.S.C. 215(a)(3). His suit was dismissed with prejudice. The judge stated that Chapman had not addressed all of the relevant factors. The Seventh Circuit affirmed. While federal court plaintiffs need not plead all legal elements plus facts corresponding to each, Chapman’s claim was implausible because it did not allege any direct dealings between himself and Yellow Cab. When the court requested more, Chapman did not respond with a plausible claim. He failed to provide additional details, insisting that, because Yellow Cab affected his driving through the chain of leases, it must be his employer.