Coleman v. Big Truck Rehab Center, Inc.

2024 Ohio 957, 237 N.E.3d 959
CourtOhio Court of Appeals
DecidedMarch 14, 2024
Docket112964
StatusPublished

This text of 2024 Ohio 957 (Coleman v. Big Truck Rehab Center, Inc.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Coleman v. Big Truck Rehab Center, Inc., 2024 Ohio 957, 237 N.E.3d 959 (Ohio Ct. App. 2024).

Opinion

[Cite as Coleman v. Big Truck Rehab Center, Inc., 2024-Ohio-957.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

ERIK COLEMAN, :

Plaintiff-Appellant, : No. 112964 v. :

BIG TRUCK REHAB CENTER, INC., ET AL., :

Defendants-Appellees. :

JOURNAL ENTRY AND OPINION

JUDGMENT: AFFIRMED RELEASED AND JOURNALIZED: March 14, 2024

Civil Appeal from the Cuyahoga County Court of Common Pleas Case No. CV-22-959255

Appearances:

Argie, D’ Amico & Vitantonio, George J. Argie, and Dominic J. Vitantonio, for appellant.

Dworken & Bernstein Co., L.P.A., and Richard N. Selby, II, for appellees.

EMANUELLA D. GROVES, J.:

Plaintiff-appellant Erik Coleman (“Appellant”) appeals the trial

court’s decision that he was an independent contractor as opposed to an employee of defendants-appellees Big Truck Rehab Center, Inc., Big Truck Cleanups & Details

LLC, and Craig A. Long (“Appellees”). For the reasons that follow, we affirm.

Facts and Procedural History

On February 7, 2022, Appellant filed a complaint against Appellees

claiming he was entitled to unpaid overtime compensation pursuant to the Federal

Fair Labor Standards Act of 1938, as amended, 29 U.S.C. 201 et seq. (“Federal

FLSA”), the Ohio Minimum Wage Standards Act (“OMWSA”), R.C. 4111.01 et seq.

and U.S. Constitution Article II, Section 34 and to recover wages under R.C. 4113.15.

The Appellees denied the claims and alleged the Appellant was an independent

contractor.

On March 22, 2023, a bench trial was held. The Appellant, his wife

and father, Appellee Craig Long, and three employees of Appellees testified. The

trial court found the following facts based upon the testimony and evidence

presented:

Appellee Craig Long, is the sole owner of both Appellees, Big Truck Rehab Center, Inc. and Big Truck Cleanups & Details LLC.

These companies provide detailing services of cleaning, washing and buffing trucks.

The Appellant and Appellee Craig Long, executed an independent contractor agreement in August 2014.

The Appellant performed detailing services under the agreement until May 2021. Appellant also worked for numerous other businesses.

All the businesses provided Appellant a 1099 tax form rather than a W- 2. For the years 2015 through 2021, Appellees provided Appellant a 1099 tax form. Additionally, Appellant was the sole proprietor of EC Detailing, per the tax records presented at trial. EC Detailing had a separate employer Tax ID Number and took deductions for expenses including supplies, materials and depreciation.

The trial court found in favor of the Appellees. Appellant appeals and

raises one assignment of error.

Assignment of Error

The trial court erred in finding that Appellant Erik Coleman, was an independent contractor, as opposed to an employee.

Standard of Review

We apply a manifest weight standard in reviewing a civil appeal from

a bench trial. Revilo Tyluka, LLC v. Simon Roofing & Sheet Metal Corp., 193 Ohio

App.3d 535, 2011-Ohio-1922, 952 N.E.2d 1181, ¶ 5 (8th Dist.), citing Seasons Coal

v. Cleveland, 10 Ohio St.3d 77, 461 N.E. 2d 1273 (1984), and App.R. 12(C).

Law and Analysis

The sole issue before this court is the employment relationship

between the Appellant and Appellees. The determination of the relationship affects

the Appellees’ obligations to the Appellant. Appellant alleges Appellees are

obligated to pay him overtime pursuant to the Federal FLSA, 29 U.S.C. 201 et seq.,

the OMWSA, R.C. 4111.01 et seq., U.S. Constitution Article II, Section 34, and wages

under R.C. 4113.15.

The OMWSA requires an employer to pay overtime to employees of a

certain type. Porter v. AJ Auto Grp., 8th Dist. Cuyahoga No. 102448, 2015-Ohio-

3769. “Except as provided in section 4111.031 of the Revised Code, an employer shall pay an employee overtime at a wage rate of one and one-half times the

employee’s wage rate for hours worked in excess of forty hours in one workweek, in

the manner and methods provided in and subject to the exemptions of section 7 and,

section 13 of the ‘Federal Fair Labor Standards Act of 1938,’ 52 Stat.1060, 29

U.S.C.A., 213, as amended.” R.C. 4111.03(A). An employee is any person employed

by an employer, with certain employees exempted. R.C. 4111.03(D)(3).

However, persons claiming employee status must prove they are

employees. Wade-Hairston v. Franklin Cty. Bd. of Mental Retardation &

Developmental Disabilities, 10th Dist. Franklin No. 98AP-456, 1998 Ohio App.

LEXIS 6223, 9 (Dec. 17, 1998), citing Anderson v. Mt. Clemens Pottery Co., 328 U.S.

680, 66 S.Ct. 1187, 90 L.Ed.1515 (1946).

The right to control the manner or means of performing the work is

the chief test in determining whether one is an employee or an independent

contractor. State ex rel. Nese v. State Teachers Retirement Bd. of Ohio, 136 Ohio

St.3d 103, 2013-Ohio-1777, 991 N.E.2d 218 ¶ 33, citing, Bobik v. Indus. Comm., 146

Ohio St. 187, 64 N.E.2d 829 (1946), paragraph one of the syllabus. See also Foran

v. Fisher Foods, Inc., 17 Ohio St.3d 193, 478 N.E.2d 998 (1985). As a practical

matter, even with independent contractors, the employer must reserve a certain

degree of control to ensure work is completed in compliance of specifications. Id.

¶ 34, citing Gillum v. Indus. Comm., 141 Ohio St. 373, 48 N.E.2d 234 (1943). In

Ohio, the test to consider in making this determination is set forth in Bostic v.

Connor, 37 Ohio St.3d 144, 524 N.E.2d 881 (1988). This test includes but is not limited to the consideration of these factors: who sets the hours worked; who selects

the tools, materials, routes traveled and human resources; length of employment;

how person is paid; type of operations; and any terms and conditions or contracts.

State ex rel. Nese at ¶ 35, citing Bostic at 146, 524 N.E.2d 881.

The trial court and parties reference application of the economic

reality test in making the decision whether the employment relationship is employee

or independent contractor. However, this test is from the United States Sixth

Circuit. Wade-Hairston at 10. Notably, Ohio has adopted its own test as set forth

in Bostic. Id. See Gradijan v. Bay, 5th Dist. Stark No. 2010CA00177, 2011-Ohio-

1032, ¶ 25-27. Although Bostic is a workers’ compensation case, both Wade-

Hairston, from the Tenth District, and Gradijan, from the Fifth District, which are

overtime and prompt payment cases, respectively, adopted the Bostic test. Now,

this court too adopts the Bostic test, as opposed to the economic reality test in

determining the employment relationship for claims of overtime and prompt

payment. This court has applied Bostic in other employment relationships dealing

with other situations, but not overtime nor prompt payment. See Silver v. Statz, 166

Ohio App.3d 148, 2006-Ohio-1727,

Related

Anderson v. Mt. Clemens Pottery Co.
328 U.S. 680 (Supreme Court, 1946)
State ex rel. Nese v. State Teachers Retirement Bd. of Ohio
2013 Ohio 1777 (Ohio Supreme Court, 2013)
Eastley v. Volkman
2012 Ohio 2179 (Ohio Supreme Court, 2012)
Revilo Tyluka, L.L.C. v. Simon Roofing & Sheet Metal Corp.
2011 Ohio 1922 (Ohio Court of Appeals, 2011)
Silver v. Statz
849 N.E.2d 320 (Ohio Court of Appeals, 2006)
Gillum v. Industrial Commission
48 N.E.2d 234 (Ohio Supreme Court, 1943)
Bobik v. Industrial Commission
64 N.E.2d 829 (Ohio Supreme Court, 1946)
Seasons Coal Co. v. City of Cleveland
461 N.E.2d 1273 (Ohio Supreme Court, 1984)
Foran v. Fisher Foods, Inc.
478 N.E.2d 998 (Ohio Supreme Court, 1985)
Bostic v. Connor
524 N.E.2d 881 (Ohio Supreme Court, 1988)
State v. Thompkins
678 N.E.2d 541 (Ohio Supreme Court, 1997)

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2024 Ohio 957, 237 N.E.3d 959, Counsel Stack Legal Research, https://law.counselstack.com/opinion/coleman-v-big-truck-rehab-center-inc-ohioctapp-2024.