Joshua Johnson v. Parks-Floyd Investments, LLC d/b/a Village Lodge

Summary

The United States District Court for the District of New Mexico denied Defendant Parks-Floyd Investments, LLC d/b/a Village Lodge’s motion for summary judgment in Joshua Johnson’s action concerning alleged unpaid overtime and retaliation under the Fair Labor Standards Act. The court held that genuine disputes of material fact remained regarding FLSA enterprise and individual coverage, Johnson’s status as an employee or independent contractor, and the elements of his overtime claim. The court also declined to resolve the disputed facts concerning Johnson’s work hours, compensation, and termination at the summary judgment stage.

Holdings

1. Village Lodge was not entitled to summary judgment on enterprise coverage because a genuine dispute remained regarding whether its annual gross volume of business reached the statutory threshold.
2. Village Lodge was not entitled to summary judgment on individual FLSA coverage because factual disputes remained regarding whether Johnson regularly participated in interstate commerce.
3. Village Lodge was not entitled to summary judgment on whether Johnson was an employee covered by the FLSA or an independent contractor.
4. Johnson's alleged lack of a specifically fixed workweek did not, by itself, defeat his overtime claim or entitle Village Lodge to summary judgment.
5. Johnson presented sufficient evidence to create a just and reasonable inference that he performed uncompensated overtime work, and Village Lodge's assertion that it paid all invoices was insufficient to warrant summary judgment.
6. Johnson established a prima facie case of FLSA retaliation, and Village Lodge failed to provide a legitimate, non-retaliatory reason for terminating him; summary judgment was therefore denied on the retaliation claim.

Questions Presented

1. Whether Village Lodge was entitled to summary judgment on the overtime claim because the record established that it was not a covered enterprise under the FLSA.
2. Whether Village Lodge was entitled to summary judgment because Johnson was not individually covered by the FLSA.
3. Whether the undisputed facts established that Johnson was an independent contractor rather than an employee under the FLSA.
4. Whether Johnson's lack of an expressly fixed workweek or the employer's assertion that it paid all invoices entitled Village Lodge to summary judgment on the overtime claim.
5. Whether Village Lodge was entitled to summary judgment on Johnson's FLSA retaliation claim.

Disposition

other