Engelhardt v. SP Richards et al.

2005 DNH 171
CourtDistrict Court, D. New Hampshire
DecidedDecember 29, 2005
DocketCV-04-120-PB
StatusPublished

This text of 2005 DNH 171 (Engelhardt v. SP Richards et al.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Engelhardt v. SP Richards et al., 2005 DNH 171 (D.N.H. 2005).

Opinion

Engelhardt v . SP Richards et a l . CV-04-120-PB 12/29/05

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Leeanne Engelhardt

v. Case N o . 04-cv-120-PB Opinion N o . 2005 DNH 171 S.P. Richards Company, Inc. and Genuine Parts Company

MEMORANDUM AND ORDER

Leeanne Engelhardt alleges that S.P. Richards Company, Inc.

(“SPR”) and its parent corporation, Genuine Parts Company

(“GPC”), violated the Family and Medical Leave Act (“FMLA”) by

terminating her employment after she missed work to care for her

daughter. Because the SPR facility where Engelhardt worked has

fewer than 50 employees, Engelhardt is not eligible for

protection under the FMLA unless her employer employs at least 50

employees within 75 miles of her worksite. Engelhardt seeks to

satisfy this requirement by counting employees of GPC. Whether

she is entitled to do so depends upon whether SPR and GPC qualify

as an “integrated employer.” The parties have raised the issue

in cross-motions for summary judgment. -2- I. BACKGROUND

A. Corporate Structure

GPC is a publicly-traded corporation based in Atlanta,

Georgia. It is the parent corporation for several subsidiaries,

including SPR. It also operates an auto parts business under the

name NAPA Auto Parts (“NAPA”). SPR is based in Symerna, Georgia.

It is a wholesaler and distributor of office supply products.

GPC and SPR have separate officers, registered agents, managers,

and employees. They have separate boards of directors, with only

two overlapping members. They also maintain separate books and

records. Each company has its own Human Resources department and

is solely responsible for its own hiring and firing decisions.

GPC administers several employee benefit plans, including

group health insurance, life insurance, 401(k) and pension plans.

SPR’s employees are eligible to participate in these plans and

SPR periodically reimburses GPC for the costs of any benefits

that its employees receive.

SPR has its own payroll department but its employees are

paid from a GPC payroll account. SPR reimburses GPC for all

funds paid to SPR’s employees. GPC also charges SPR an

administrative fee to cover its processing costs.

-3- SPR has adopted GPC’s policies on attendance, sexual

harassment, substance abuse, corporate conduct and network

security. SPR decided on its own to adopt these policies.

SPR employs fewer than 50 employees at its Nashua, New

Hampshire distribution facility. GPC employs more than 50

employees at facilities located within 75 miles of SPR’s Nashua

facility.

B. Engelhardt’s Employment

SPR hired Engelhardt as a customer service representative at

its Nashua distribution facility in February 2000. On January

1 7 , 2000, Engelhardt signed a “Genuine Parts Company Applicant

Acknowledgment of Substance Abuse Policy.” On October 8 , 2001,

she signed an acknowledgment that she had received and agreed to

abide by the “Genuine Parts Company Code of Corporate Conduct.”

On March 2 6 , 2002, she signed an acknowledgment bearing the “S.P.

Richards Co.” name and stating that she had received and agreed

to abide by the “Genuine Parts Company Employee Attendance

Policy.”

SPR terminated Engelhardt’s employment on December 1 7 , 2002,

after she missed work the previous day to care for her daughter.

The decision to terminate Engelhardt was made exclusively by

-4- employees of SPR.

II. STANDARD OF REVIEW

Summary judgment is appropriate only “if the pleadings,

depositions, answers to interrogatories, and admissions on file,

together with the affidavits, if any, show that there is no

genuine issue as to any material fact and that the moving party

is entitled to a judgment as a matter of law.” Fed. R. Civ. P.

56(c). A genuine issue is one “that properly can be resolved

only by a finder of fact because [it] may reasonably be resolved

in favor of either party.” Anderson v . Liberty Lobby, Inc., 477

U.S. 2 4 2 , 250 (1986). A material fact is one “that might affect

the outcome of the suit.” Id. at 248. When considering a

defendant’s motion for summary judgment, “[t]he mere existence of

a scintilla of evidence in support of the plaintiff’s position

[is] insufficient; there must be evidence on which the jury could

reasonably find for the plaintiff.” Id. at 252.

III. ANALYSIS

To be eligible for protection under the FMLA, an employee

must work for an employer that employs at least 50 workers within

-5- 75 miles of the employee’s worksite. 29 U.S.C. § 2611(2)(B)(ii).

In most circumstances, “the legal entity which employs the

employee is the employer under FMLA.” 29 C.F.R. § 825.104(c).

An exception exists, however, if a parent and a subsidiary

qualify as an “integrated employer.” Id. § 825.104(c)(1).

To determine whether separate corporate entities are an

integrated employer, the court must review the entities’

relationship in its totality. Id. § 825.104(c)(2). The

following factors are considered: “(i) Common management; (ii)

Interrelation between operations; (iii) Centralized control of

labor relations; and (iv) Degree of common ownership/financial

control.” Id. The First Circuit has followed a flexible

approach when using this test in which all four factors are

considered but control of labor relations is the primary

consideration. Romano v . U-Haul Int’l, 233 F.3d 655, 666 (1st

Cir. 2000).

Applying the flexible approach mandated by the First Circuit

to the undisputed facts, it is apparent that SPR and GPC are not

an integrated employer. First, although Engelhardt argues that

GPC should be treated as her employer because SPR adopted several

of GPC’s employment policies, I agree with the Tenth Circuit that

-6- “[a] parent’s broad general policy statements regarding

employment matters are not enough to satisfy [the control over

labor relations factor].” Frank v . U.S. West, Inc., 3 F.3d 1357,

1363 (10th Cir. 1993). Instead, the facts that are determinative

here are that: (1) GPC and SPR each have their own Human

Resources departments; (2) each company is solely responsible for

its hiring and firing decisions; (3) SPR manages day-to-day

operations at the Nashua facility where Engelhardt worked; and

(5) SPR’s employees made the decision to terminate Engelhardt

without consulting anyone at GPC. Taken together, these facts

convincingly demonstrate that SPR was responsible for its own

labor relations.

A second factor that favors the defendants is the absence of

common management. As I have noted, GPC and SPR each have their

own officers, managers and employees. Only two directors sit on

both companies’ boards of directors. Each company has its own

headquarters. Further, Engelhardt has produced no evidence that

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