Gennell et al v. FedEx

2013 DNH 110
CourtDistrict Court, D. New Hampshire
DecidedSeptember 10, 2013
DocketCV-05-145-PB
StatusPublished
Cited by1 cases

This text of 2013 DNH 110 (Gennell et al v. FedEx) 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
Gennell et al v. FedEx, 2013 DNH 110 (D.N.H. 2013).

Opinion

Gennell et al v . FedEx CV-05-145-PB 9/10/13 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Robert Gennell, Jr. et a l .

v. Case N o . 05-cv-145-PB Opinion N o . 2013 DNH 110 FedEx Ground Package System, Inc.

AMENDED MEMORANDUM AND ORDER

This class action was filed against FedEx Ground Package

System, Inc. (“FedEx”) by several FedEx drivers based in New

Hampshire who claim that FedEx improperly treated them as

independent contractors rather than employees. The action was

centralized in a multidistrict litigation proceeding with other

similar actions against FedEx. The transferee court later

determined that the New Hampshire drivers could be treated as

independent contractors under New Hampshire common law but that

they qualified as employees under certain state statutes. It

then remanded the action to this court.

Two class claims remain in dispute. Plaintiffs allege in

their second cause of action (“Deduction Claim”) that FedEx made

deductions from the drivers’ compensation that were prohibited by N.H. Rev. Stat. Ann. § 275:48. They allege in their eighth

cause of action (“Reimbursement Claim”) that FedEx failed to

reimburse the drivers for work-related expenses in violation of

N.H. Rev. Stat. Ann. § 275:57. 1 FedEx has filed a motion for

summary judgment contending that both claims are preempted by

the Federal Aviation Administration Authorization Act of 1994

(“FAAAA”). It also argues that the Reimbursement Claim is

deficient even if it is not preempted. Plaintiffs have filed

their own motion for partial summary judgment.

I. BACKGROUND

A. The Relationship between FedEx and Drivers

FedEx is a nationwide small package pick-up and delivery

company. During the class period, the company conducted its

business delivery operations under the name “FedEx Ground”

(“FEG”) and its home delivery operations under the name “FedEx

Home Delivery” (“FHD”). The class includes New Hampshire

1 The parties agree that plaintiffs’ fifth cause of action for rescission is foreclosed by the transferee court’s ruling, their first cause of action for failure to pay overtime and provide meal breaks and their fourth cause of action alleging a violation of New Hampshire’s Consumer Protection Statute fail under New Hampshire law, and their sixth and seventh causes of action for an accounting and declaratory judgment do not state independent claims for relief. Plaintiffs’ third cause of action for fraud is not a class claim and is not at issue at the present time.

2 drivers from both FEG and FHD who worked for FedEx as

independent contractors between April 2 7 , 2002 and June 1 , 2009.

In re FedEx Ground Package Sys., Inc. Emp’t Practices Litig.,

273 F.R.D. 4 2 4 , 470–72 (N.D. Ind. 2008); T r . 5. 2

FedEx entered into a standard-form “Operating Agreement”

(“OA”) with each class member. See Doc. N o . 53-3. The OA

characterizes the drivers as independent contractors. Doc. N o .

53-3 at 6 (“Both [FedEx] and Contractor intend that Contractor

will provide these services strictly as an independent

contractor, and not as an employee of [FedEx] for any

purpose.”). The drivers, nevertheless, agreed to conduct their

business in a manner that identified them as part of the FedEx

system. The OA “set[s] forth the mutual business objectives of

the two parties . . . but the manner and means of reaching [the]

results are within the discretion of the Contractor.” Doc. N o .

53-3 at 6.

2 Plaintiffs proposed, and the MDL court granted certification for, a class period starting on April 2 7 , 2002 with no specified end date. In re FedEx, 273 F.R.D. at 4 7 0 , 472. FedEx’s brief describes the class period as running from April 2 7 , 2002 to May 3 1 , 2009. Doc. N o . 53 at 3 0 . At oral argument, the parties agreed that the class period ended on June 1 , 2009, the date FedEx switched to a different business model in New Hampshire. Tr. 4–5. The class period was incorrectly described at oral argument as starting on April 2 9 , 2002. The correct start date is April 2 7 , 2002, as stated in the MDL class certification order. In re FedEx, 273 F.R.D. at 4 7 0 , 472.

3 The drivers agreed to render their services using a FedEx

terminal in New Hampshire as their home base. See id. at 2 1 .

They were required to fill out daily logs and inspection reports

and file the originals with FedEx at the end of each business

day. Id. at 9. The drivers also had to meet an “Agreed

Standard of Service,” which included cooperating with FedEx

employees, maintaining the professional image and good

reputation of FedEx, and conducting all business activities with

integrity and honesty. Id. at 10–12. The OA restricted drivers

from using their equipment for any other purpose while the

equipment was in the service of FedEx. Id. at 8 .

FedEx compensated the drivers through weekly settlement

payments. The settlement payments were calculated using a

compensation formula that took into account the volume of the

drivers’ package deliveries, the number of stops they made, and

the density of their delivery area, and deducted certain

expenses FedEx incurred on behalf of the drivers. Id. at 18–20.

Deemed “independent contractors,” the drivers were required

to procure their own trucks and operate them at their own

expense. Id. at 7 (requiring the drivers to bear all costs and

expenses of operating the trucks, including maintenance, fuel,

oil, tires, repairs, taxes, insurance, workers compensation

4 assessments, licenses, vehicle registration fees, and tolls).

The drivers were also required to mark their trucks and other

equipment with FedEx colors, logos, numbers, marks, and insignia

and wear a FedEx uniform. Id. at 8 , 1 2 . The drivers either

paid for these expenses out-of-pocket or they were deducted from

their weekly settlement payments. For instance, to facilitate

the payment of licenses, taxes, and fees, the drivers authorized

FedEx to pay the charges on the drivers’ behalf and then deduct

the expenses from their weekly settlement payments. Id. at 7–8.

Drivers could elect to participate in a business support package

(“BSP”) through which FedEx provided the drivers with uniforms,

communications equipment, Department of Transportation (“DOT”)

inspections, equipment washing, and drug tests to meet DOT

requirements. Most drivers participated in the BSP and the cost

was deducted from their weekly settlement payments. Id. at 2 4 .

If a driver did not elect to acquire the communications

equipment necessary to fulfill his obligations through the BSP,

he was required to purchase or lease i t . Id. at 1 2 .

In addition to the BSP deduction, plaintiffs allege that

FedEx deducted the cost of deadhead,3 work accident insurance,

3 Deadhead insurance is insurance to cover a tractor when it is operated without a load. Great Am. Assurance. C o . v . Sanchuk, LLC, 8:10-cv-2568-T-33AEP, 2012 WL 3112004, at *7 n.2 (M.D. Fla.

5 and cargo insurance, as well as the postage fees associated with

sending correspondence to the drivers. Doc. Nos. 46 at 11–12;

46-3 at 1 0 .

B. Plaintiffs’ Claims

Plaintiffs base the Deduction Claim on N.H. Rev. Stat. Ann.

§ 275:48 (“Deduction Statute”), which bars an employer from

withholding or diverting money from an employee’s wages unless

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Related

Gennell v FedEx Corp et al
D. New Hampshire, 2014

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