Federal Court Dismisses Franchisor from Wage Suit for Conclusory Joint-Employer Allegations

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A federal court in Ohio dismissed wage-and-hour claims brought by a former employee of a Glass Doctor franchisee against Synergistic International LLC because the complaint inadequately pleaded Synergistic’s liability for the franchisee’s conduct. Little v. Serv. Convenience, Inc., 2025 WL 3706411 (S.D. Ohio Dec. 22, 2025).

Shiro Little alleged she worked as an inside sales associate for a franchised Glass Doctor location in Ohio and was repeatedly paid late and, at least once, not paid at all. She sued the Glass Doctor franchisee, Service Convenience, Inc., and Synergistic, which she alleged franchised the Glass Doctor system, asserting claims under the Fair Labor Standards Act and Ohio wage laws.

The court held that Little’s joint-employer theory against Synergistic rested on “naked” and “conclusory” allegations. Little largely recited the types of factors courts consider when assessing joint employment, such as authority over hiring and discipline, control over pay, and supervision, but did not plead facts showing Synergistic actually exercised control over Little’s employment or payroll. Instead, the complaint’s factual allegations expressly tied payroll responsibility to the franchisee, alleging that the franchisee’s owner was ultimately responsible for payroll and accepted responsibility for the pay issues. Because the pleading lacked factual content supporting a plausible inference that Synergistic was a joint employer under the FLSA, the court dismissed the FLSA claim against Synergistic and dismissed the related Ohio wage-law claims under the same analysis. The court dismissed the claims against Synergistic without prejudice and allowed Little 21 days to seek leave to amend to plead facts supporting joint-employer status, with the dismissal converting to one with prejudice if she did not do so.

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