Chapman v. Yellow Cab Coop. - 875 F.3d 846 (7th Cir. 2017)

Rule:

Ever since their adoption in 1938, the Federal Rules of Civil Procedure have required plaintiffs to plead claims rather than facts corresponding to the elements of a legal theory. Fed. R. Civ. P. 8. Old code-pleading and fact-pleading systems have been abandoned. Because complaints need not identify the applicable law, it is manifestly inappropriate for a district court to demand that complaints contain all legal elements (or factors) plus facts corresponding to each.

Facts:

Dennis Edwards owned a taxicab. Defendant Yellow Cab Cooperative referred business to his cab; other arrangements between Edwards and defendant were not in the record. Edwards leased the cab to one Parashu Giri, who subleased some of the time to plaintiff Thomas Edward Chapman. Apparently, Giri and plaintiff shared the cab so that it could be in service much of the day. Plaintiff received fares and tips from passengers, paid rent to Giri, and kept the difference but he did not pay anything to defendant or receive anything from it. However, plaintiff contended in this suit under the Fair Labor Standards Act that this arrangement made him an employee of defendant. He alleged that after he complained about not receiving the minimum wage, defendant Ali Mohamed, the President of Yellow Cab, told Giri that plaintiff was fired. Giri then terminated the sublease. Plaintiff submitted that defendant president’s action violated the Act's antiretaliation clause. The district judge dismissed all of plaintiff’s other theories and directed him to file a new complaint. The amended complaint was assigned to another judge, who concluded that plaintiff must provide more detailed and thorough allegations before the claim can be permitted to proceed. The judge stated that the complaint had not discussed all of the factors identified in one case as potentially relevant to the distinction between an employee and an independent contractor. Because plaintiff’s allegations, even construed liberally, did not address these factors, the judge ordered plaintiff to file yet another complaint. The final version was filed and it was dismissed with prejudice. 

Issue:

Was the dismissal of the suit with prejudice proper?

Answer:

Yes.

Conclusion:

The court affirmed the judgment. The court ruled that the lower court erred to the extent that it demanded that plaintiff plead facts to support his antiretaliation claim under the Fair Labor Standards Act, 29 U.S.C.S. § 215(a)(3). The court held that Fed. R. Civ. P. 8 merely required notice pleading. Further, the court held that while plaintiff's claim seemed implausible, it was not dismissed based on implausibility. The order was treated as having been entered under Fed. R. Civ. P. 12(e). The court also found that plaintiff not only failed to provide additional details but also insisted that, because defendant affected or controlled his driving through a chain of leases, defendant had to be his employer, thus, equating regulatory authority with employment had been rejected. Lastly, plaintiff added a legal theory that made his claim less plausible, and the court properly dismissed the suit with prejudice after plaintiff's multiple failed efforts to frame a plausible claim.