July 08, 2026|Franchise Frontlines
July 8, 2026 | United States District Court for the Southern District of Ohio, Eastern Division | Slip Copy — Not Yet Reported (2026 WL 1970852)
Executive Summary
In a slip-copy opinion not yet reported (2026 WL 1970852), Chief Judge Sarah D. Morrison of the United States District Court for the Southern District of Ohio, Eastern Division, granted the defendants’ motion to dismiss and dismissed a remote employee’s state-law employment suit in its entirety. Kiera Robinson brought race-discrimination and retaliation claims under Ohio Revised Code § 4112 against SmartThings, Inc., which she identified as her direct employer, and Samsung Electronics America, Inc., which she identified as SmartThings’s parent company. SmartThings moved to dismiss for lack of personal jurisdiction, arguing that hiring a remote worker who chose to live in Ohio did not amount to transacting business in the State; Samsung moved to dismiss for failure to state a claim, arguing that it was not Robinson’s employer and could not be held liable for SmartThings’s conduct. Robinson did not respond to the motion, and her deadline passed. The court held that it lacked personal jurisdiction over SmartThings because Robinson identified no basis under Ohio’s long-arm statute, and that Robinson failed to state a claim against Samsung because she pleaded no facts supporting single or integrated employer, joint employer, or agency liability; it therefore dismissed the complaint.
Relevant Background
SmartThings hired Robinson as a remote employee in March 2022. In April 2023, she was transferred to a new team on which she was the only Black employee, and, according to the complaint, she was subjected to differential treatment that included abrasive comments and dismissive remarks. Even so, she received positive performance reviews and financial bonuses during this period.
Robinson’s work environment did not improve. In early to mid-2024 she experienced issues with a higher-level coworker and reported her concerns to human resources without result. In August 2024 she received a significantly lower performance review containing criticisms that had not previously been communicated to her, and she made multiple requests for a team transfer or other accommodations to address what she described as a hostile work environment. SmartThings denied those requests and instead recommended a “mentorship” program to address her alleged performance deficiencies. Robinson was encouraged to find new employment and filed a formal charge with the Equal Employment Opportunity Commission; the complaint alleges that SmartThings terminated her in June 2024 for “performance issues.”
Robinson sued SmartThings and Samsung, which she identified as SmartThings’s parent company, asserting two claims under Ohio Revised Code § 4112 for race discrimination and retaliation. SmartThings moved to dismiss for lack of personal jurisdiction, and both defendants moved to dismiss for failure to state a claim. Robinson did not respond to the motion, and her deadline passed before the court ruled.
Decision
The court began with SmartThings’s Rule 12(b)(2) challenge. On written submissions, it explained, a plaintiff bears a “relatively slight” burden and “must make only a prima facie showing that personal jurisdiction exists in order to defeat dismissal.” Sitting in diversity, the court could exercise jurisdiction over an out-of-state defendant only if an Ohio court could, which required satisfying both Ohio’s long-arm statute and constitutional due process. Because Robinson had not shown jurisdiction under the long-arm statute, the court did not reach due process. It found no general jurisdiction: Robinson did not allege that SmartThings was an Ohio corporation, that its principal place of business was in Ohio, or that its Ohio affiliations were so “continuous and systematic” as to render it at home in the State.
Turning to specific jurisdiction, the court noted that Ohio’s long-arm statute lists nine bases and—because Robinson did not respond—examined only her complaint to identify any that might apply. It determined that the “only plausible basis” was that SmartThings “[t]ransact[ed] … business in this state,” a “broad” inquiry calling for a case-by-case determination. Relying on its own prior decision in Carpenter v. S. Airways Express, the court reasoned that an employer of a remote worker is “agnostic as to where she worked”—it “chose to hire her, and she chose to live in Ohio.” Robinson did not allege that her position was based on her living in Ohio or that she worked on Ohio-specific matters, and her remaining allegations focused on SmartThings’s assertedly discriminatory actions, “not on its relationship with the State of Ohio.” The court accordingly granted SmartThings’s motion.
The court next addressed Samsung’s Rule 12(b)(6) motion under the plausibility standard of Twombly and Iqbal. Because Ohio courts interpret § 4112 in accordance with Title VII, which “applies only to ‘employers,’” the threshold question was whether Robinson had alleged facts making Samsung her employer. She had alleged only that SmartThings hired and terminated her and that Samsung was SmartThings’s parent—not that she worked directly for Samsung. Citing Swallows v. Barnes & Noble Book Stores, Inc., the court identified three doctrines under which an entity that does not directly employ a plaintiff may still be considered an employer: where two entities are so interrelated that they may be considered a single or integrated employer; where one company has control over another’s employees sufficient to make the two a joint employer; and where the direct employer acted as the other company’s agent. Robinson, the court found, “has not alleged that any of the three apply here.”
The court likewise rejected parent-company liability. Under Title VII, holding a parent liable for a subsidiary’s acts requires “sufficient indicia of an interrelationship between the immediate corporate employer and the affiliated corporation” to support an aggrieved employee’s belief that the affiliate is “jointly responsible” for the immediate employer’s acts. Robinson pleaded no facts suggesting that Samsung and SmartThings were interrelated or that Samsung “controls the day-to-day activities of SmartThings’s employees.” Having found no plausible basis for treating Samsung as an employer, the court granted Samsung’s motion, dismissed both counts, and declined to reach whether Robinson had exhausted her administrative remedies. The complaint was dismissed in full.
Looking Forward
Although Robinson is an unreported trial-court decision applying Ohio law to a parent-subsidiary technology company, its reasoning may inform how courts approach the recurring effort to hold a larger, non-employing entity responsible for a direct employer’s alleged workplace conduct—a pattern franchisors know well. The court’s insistence that a corporate relationship, standing alone, does not create employer status echoes the defenses franchisors raise against joint-employer and integrated-enterprise theories. Nothing in the opinion binds courts outside Ohio, and franchisors should treat it as persuasive and analogous rather than controlling, but its framework is a useful reference point.
The decision underscores that a plaintiff who names a parent, brand owner, or franchisor alongside the direct employer must plead entity-specific facts, not merely the existence of a corporate or brand relationship. On this record, the court required something more than the parent-subsidiary label—interrelation sufficient to constitute a single or integrated employer, control amounting to joint employment, or an agency relationship—before a non-employing entity could be drawn in, and it dismissed where the complaint offered only that label. For franchisors, the analogy—while only an analogy—is close: brand ownership and system standards, absent allegations that the franchisor controls a franchisee’s day-to-day labor decisions, may not by themselves support employer liability. The defensive practice point is a familiar one, reinforced here: preserve genuine separation in both documents and operations, and keep hiring, firing, discipline, supervision, and similar decisions with the direct employer, so that a plaintiff cannot readily recast an ownership or licensing relationship as codetermination or integration.
The jurisdictional holding offers a second, narrower lesson for employers and branded systems with distributed workforces. The court concluded that, on this record, hiring a remote worker who chose to live in Ohio did not by itself show that the employer “transacted business” there, reasoning that the employer was “agnostic” as to where the employee worked. Employers with remote staff scattered across the country may find that reasoning helpful in resisting suit in a forum whose only connection is the employee’s chosen residence, but they should not overread it: the court stressed that Robinson pleaded nothing more, and a different record showing purposeful local activity, forum-specific work, or other deliberate contacts could support jurisdiction. The prudent course remains disciplined attention to where a company actually directs its business and prompt assertion of personal-jurisdiction defenses when a suit is filed in a state whose only tie is the employee’s chosen residence.
Thomas O’Connell is a Partner at Buchalter LLP and Chair of the firm’s Franchise Practice Group. For questions about this article or media inquiries, you can contact Tom at toconnell@buchalter.com.
This article is based solely on the opinion of the Court in this matter. The author has not conducted any independent investigation into the facts. For the avoidance of doubt, each statement related to the law and facts in this article is drawn from the Court’s opinion in this case. It was drafted with the assistance of an artificial intelligence system. AI systems can make mistakes, including in describing legal authority. Readers should independently confirm any legal authority before relying on it.
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