Posts Tagged ‘independent contractors’

Worker Misclassification Legislation Looming in Both Houses of Congress

Sunday, May 2nd, 2010

On April 22, both houses of Congress re-introduced legislation designed to crackdown on the misclassification of workers as independent contractors. Entitled The Employee Misclassification Prevention Act, the bill will have a significant impact on employers’ current practices. If enacted, employers will be required to keep records relative to their independent contractors, specifically reflecting their status as such. Employers will also be required to provide written notice to all workers of their status as either an employee or as an independent contractor.

Additionally, the legislation would expand the Fair Labor Standards Act’s anti-retaliation provision to workers who have been discriminated against because they have sought to be accurately classified. The legislation also imposes tougher penalties of $1,100 per violation for the first offense and up to $5,000 for repeat or willful violations. Furthermore, employers who misclassify workers thereby violating minimum wage and/or maximum hour provisions of the FLSA could end up paying double the amount of liquidated damages. To ensure that workers are made aware of their rights, the bill mandates the creation of an official Department of Labor “employee rights website.” The website could make filing a claim as simple as clicking on a link and filling out a form.

Under the legislation, more cooperative efforts and the sharing of information between the Department of Labor and the Internal Revenue Service are strongly encouraged. While this bill has not yet been passed into law, employers must be cognizant of the continued focus on and the possible ramifications of worker misclassification.

Massachusetts Attorney General’s Office Reaches Settlements in Four Wage Hour Cases Involving Restaurant Delivery Companies

Sunday, February 7th, 2010

Simultaneous with the launch of the IRS’s new initiative on worker misclassification, Attorney General Martha Coakley’s Office announced, just this past week, that it reached settlements in four separate misclassification cases. In each of these cases, the Attorney General’s Office claimed that restaurant delivery companies had misclassified their drivers as independent contractors when they should have been classified as employees. Because of this misclassification, the Attorney General’s Office opined that these workers were deprived of certain wage/hour protections as well as other benefits that employees enjoy, such as unemployment insurance, workers’ compensation benefits and health insurance.

Beginning last June and continuing into the present, the Fair Labor Division of the Attorney General’s Office has ramped up its enforcement efforts, particularly with regard to misclassification. Specifically, the Attorney General’s Office has targeted various meal delivery companies in Massachusetts, focusing their investigations on the companies’ classification of workers.

The companies under investigation may have decided to settle their cases with the Attorney General’s Office to avoid the extremely steep penalties misclassification creates. Indeed, misclassification leads to the automatic imposition of triple damages under the Massachusetts Wage Act regardless of whether it was deliberate or accidental.

To read the AG’s full press release, click here.

Proposed DOL budget includes increase in funds for “worker protection programs”

Friday, February 5th, 2010

The recently-proposed FY 2011 budget for the Department of Labor requests $117 billion in funds, including $13.9 billion in “discretionary funding.” Although the $117 billion request is less than what the DOL received last year, the DOL has requested $1.7 billion for worker protection programs, up 4% from last year.

The DOL’s proposal includes a plan to hire at least 350 employees, and more than half of them would work in investigations and enforcement. The DOL has expressed a commitment to increasing its efforts in several areas, including Office of Federal Contract Compliance Programs (OFCCP) compliance and worker misclassification. In fact, the proposed budget includes a request for $25 million for a joint initiative between the DOL and the Treasury Department to combat misclassification of employees as independent contractors. This initiative proposes to add an additional 90 employees in the DOL’s wage and hour division as well as 10 employees to support litigation efforts by the Solicitor of Labor. The OFCCP intends to hire additional staff as well to maintain its aggressive investigation and enforcement efforts.

While some praise the administration’s efforts to enhance worker protection programs, others have suggested that, given the current state of the economy, these programs may unjustifiably burden and punish employers. It will be interesting to see how the DOL’s proposed budget compares to the budget that eventually is approved by Congress. We’ll be sure to provide updates as developments occur.

Learning the Hard Way: the SJC’s recent reminder that worker misclassification costs big bucks

Saturday, September 12th, 2009

If it looks like a duck and quacks like a duck, guess what – it is a duck.  This means that you can’t try to call it a fish, because it just isn’t.  This old adage so aptly describes situations where workers are misclassified as independent contractors when they really are employees.  No matter how much an employer wants to call them an independent contractor, if they do not meet the independent contractor test, they are just not one, period.

Misclassification, even when unintentional, leads to violations of several different laws and exposes employers to massive liability.  In fact, one of those laws – the Massachusetts Wage Act – provides for triple damages regardless of whether the violation was deliberate or accidental.  The Massachusetts Supreme Judicial Court’s (“SJC”) recent decision in Somers v. Converged Access, Inc. serves as an important reminder that the independent contractor statute is meant to be a strict liability statute.

In this case, Somers, who had unsuccessfully applied for employment with Converged Access, Inc. (“CAI”) on two occasions, was ultimately hired as an independent contractor, doing work similar to that of CAI employees.  As an independent contractor, Somers did not receive employee benefits, such as time off from work, health insurance or retirement benefits, and Somers did not receive overtime pay when he worked more than 40 hours per week. CAI did not withhold taxes from Somers’ pay or pay workers’ compensation and unemployment insurance on behalf of Somers.  CAI did, however, pay Somers significantly more money as an “independent contractor” than it ever would have as an employee.

When CAI chose not to renew Somers’ contract, Somers filed suit under the Massachusetts Wage Act, claiming that, as an independent contractor, he did not receive the wages and benefits that CAI employees had, such as overtime pay and vacation time.  In response, although CAI did not dispute that Somers was incorrectly classified, it argued that because Somers was earning substantially more money than its employees and was, in fact, paid more money than any overtime he would have earned, Somers did not suffer any damages.  Further, CAI claimed that it would have paid Somers far less if he had been an employee.  Accordingly, CAI argued that it should be allowed an “off-set” for the salary it would have paid Somers if he was an employee against the much larger amount it paid him as an independent contractor.

Although the trial court agreed with CAI’s argument, the SJC did not.  In fact, the SJC noted that the legislative intent behind the independent contractor statute would be contravened by allowing such an off-set and reasoned that “[w]ere employers who violated the statute permitted a ‘safe harbor’ that allowed them to demonstrate that they would have paid the employee less had they known he or she was not an independent contractor, there would be no financial incentive to ensure employer compliance and employees would be left with no meaningful protection from misclassification.”  Thus, the SJC determined that it was clear that the independent contractor statute was written to impose strict liability on employers.

The case was remanded to the trial court for a determination on damages.  Because the SJC found that CAI had misclassified Somers, Somers will be able to recover triple the damages.  It will be the trial court’s job to determine exactly what damages were incurred by the misclassification, which will include any wages, overtime pay and benefits that Somers was denied because of his misclassification.

Showing independent contractor status is very difficult and entails overcoming Massachusetts law’s presumption of employment.  This case serves as a very important reminder to Massachusetts employers that there are extremely tough penalties for misclassifying workers as independent contractors.

To read the SJC’s full decision, click on the following link: http://www.sociallaw.com/slip.htm?cid=19358&sid=120