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Chapman v. Yellow Cab Cooperative

United States Court of Appeals for the Seventh Circuit
875 F.3d 846 (2017)


Facts

Yellow Cab Cooperative (defendant) referred business to a cab owner. The owner leased the cab to a driver, who in turn subleased part of the time to another driver, Thomas Chapman (plaintiff). Chapman claimed that after he complained about not making minimum wage, Yellow Cab’s president fired him. That meant Yellow Cab would no longer dispatch him to pick up people who called Yellow Cab, and the other driver terminated Chapman’s sublease. Chapman sued for retaliatory discharge under the Fair Labor Standards Act, claiming he qualified as an employee of Yellow Cab. The district court judge told Chapman to file a new complaint with more detailed and thorough allegations supporting his claim that he was an employee. Chapman filed a new complaint, but the judge again directed him to refile because he had not addressed all the factors that Seventh Circuit cases identify as relevant to distinguishing between employees and independent contractors. Chapman again refiled, but the court found his third complaint still did not address all the relevant factors and dismissed his lawsuit altogether. On appeal, Chapman submitted additional facts that made treating him as a Yellow Cab employee more plausible.

Rule of Law

Issue

Holding and Reasoning (Easterbrook J.)

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