Hargrove v. Sleepy’s, LLC

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Plaintiffs Sam Hargrove, Andre Hall, and Marco Eusebio delivered mattresses for defendant Sleepy s, LLC. Plaintiffs claimed that they were employees of Sleepy's, that Sleepy's miscategorized them as independent contractors, and that misclassification caused various financial and non-financial losses to them. Plaintiffs argued that the Independent Driver Agreement signed by each of them violated state wage laws because the contracts were a ruse to avoid payment of employee benefits, such as health insurance, deferred compensation benefits, and medical or family leave. The issue of whether plaintiffs were employees or independent contractors was submitted to the United States District Court for the District of New Jersey on cross motions for summary judgment. The federal court held that the undisputed facts demonstrated that plaintiffs were independent contractors. Plaintiffs appealed. The Court of Appeals filed a petition with the New Jersey Supreme Court seeking to certify the question of New Jersey law: which test should a court apply to determine a plaintiff's employment status, the New Jersey Wage Payment Law, N.J.S.A. 34:11-4.1, et seq., or the New Jersey Wage and Hour Law, N.J.S.A. 34:11-56a, et seq.? The New Jersey Court responded that the test derived from the New Jersey Unemployment Compensation Act, N.J.S.A.43:21-19(i)(6), governed whether a plaintiff is an employee or an independent contractor for purposes of resolving a wage-payment or wage-and-hour claim. View "Hargrove v. Sleepy's, LLC" on Justia Law