October 20, 2025|Franchise Frontlines
October 20, 2025 | U.S. District Court for the Northern District of Ohio | Unpublished Opinion
Executive Summary
In an unpublished decision, Judge Jeffrey Helmick granted summary judgment in favor of Roppe Corporation, holding that the flooring manufacturer was not the employer of several individuals with disabilities who worked for a nonprofit organization operating inside Roppe’s facility. Although the plaintiffs argued that Roppe should be treated as their employer under either the single-employer or joint-employer doctrines, the court found no factual basis for liability. The judge emphasized that business proximity, commercial interdependence, and facility-sharing are insufficient to establish an employment relationship under the ADA or its state-law analogue. Because the plaintiffs could not show that Roppe exercised hiring, firing, supervision, training, or compensation control, summary judgment was awarded in Roppe’s favor on all claims.
Relevant Background
According to the record, the plaintiffs worked for Seneca Re-Ad Industries, a nonprofit organization operating a sheltered workshop for individuals with disabilities. Seneca Re-Ad leased space inside Roppe Corporation’s manufacturing facility for a nominal fee. In that space, Seneca Re-Ad employees produced flooring samples that were sold to Roppe as part of a longstanding commercial relationship. Plaintiffs alleged that Roppe and Seneca Re-Ad functioned as a single, integrated employer and that Roppe was liable under the ADA and Ohio Revised Code § 4112.02(A) for alleged discriminatory failures in training, promotions, accommodations, and compensation.
The court noted that Roppe maintained its own workforce in separate parts of the facility, kept separate bank accounts and records, and did not participate in the daily operations of the Seneca Re-Ad workshop. Seneca Re-Ad’s workforce—including plaintiffs—was supervised by employees of the Seneca County Board of Developmental Disabilities (“SCBDD”), which contracted with Seneca Re-Ad to provide vocational services, training, and oversight. Although plaintiffs argued Roppe exerted control over the workshop by virtue of being its primary customer and by permitting use of certain equipment, the court found no evidence that Roppe directed or influenced the terms and conditions of plaintiffs’ employment.
Decision
Judge Helmick methodically applied the Sixth Circuit’s frameworks for single-employer and joint-employer liability, emphasizing that each doctrine requires specific, defendant-focused evidence of employment control.
Under the single-employer analysis, the court reviewed the four traditional factors: interrelation of operations, common management, centralized control of labor relations, and common ownership or financial control. The court held that none of these elements were satisfied. Roppe and Seneca Re-Ad maintained separate accounts, separate records, and separate workforces. The court found no evidence of common managers or officers, and noted that SCBDD—not Roppe—performed the functions plaintiffs attributed to Roppe, including training workshop staff and supervising daily operations. The fact that Seneca Re-Ad sold most of its output to Roppe or used some Roppe-owned equipment did not constitute an interrelation of operations of the type required to collapse two entities into a single employer.
The court also rejected plaintiffs’ attempt to expand the single-employer inquiry by pointing to cases involving parent-subsidiary relationships or entities sharing customers and marketing materials. Those cases, Judge Helmick explained, involved extensive overlapping management structures and control not present here.
Turning to the joint-employer theory, the court again emphasized that liability turns on control over the essential terms and conditions of employment—hiring, firing, discipline, supervision, pay, and benefits. Plaintiffs could not identify any evidence that Roppe made employment decisions for Seneca Re-Ad workers. The court found no indication that Roppe supervised plaintiffs, set their schedules, determined their pay, or had the ability to hire or fire them. Plaintiffs pointed to the fact that Roppe was Seneca Re-Ad’s only customer and that sample-making volume aligned with Roppe’s purchase orders, but the court held that economic dependence does not equate to employment control. The court also noted that plaintiffs acknowledged having no contact with Roppe employees prior to their depositions in the litigation.
Because plaintiffs could not satisfy any of the key employment-control factors, and because the record showed that SCBDD—not Roppe—managed Seneca Re-Ad’s workshop operations and employment affairs, the court concluded that no reasonable jury could find Roppe liable. Summary judgment was therefore granted in full.
Looking Forward
This decision reinforces that courts require concrete, defendant-specific evidence of employment control when evaluating single-employer and joint-employer claims. Business proximity, supply relationships, or even the co-location of a contractor’s workforce within a larger business’s facility do not suffice to create employer liability absent evidence of authority over hiring, firing, supervision, or compensation. For franchisors and multi-unit brand systems, the ruling offers several protective takeaways. Courts remain focused on the traditional employment relationship factors rather than on economic interdependence or commercial coordination. Even where two entities work closely together or share space, the absence of direct labor control is dispositive.
The ruling also illustrates why franchisors should maintain clear corporate separateness and document the boundaries between system-level standards and daily operational oversight. When plaintiffs attempt to characterize commercial influence or logistical support as employer control, courts scrutinize the record for evidence of actual authority over personnel decisions. Ensuring that franchise agreements, operating manuals, and internal procedures preserve the independence of franchisees and their employees may help avoid similar joint-employer arguments. This case demonstrates that plaintiffs cannot rely on general assertions of “influence” or “control” without evidence tied directly to employment conditions—an approach that aligns with how courts often view franchisor relationships.
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.
Thomas O’Connell is a Shareholder at Buchalter APC 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 communication is not intended to create, and does not create, an attorney-client relationship or any other legal relationship. No statement herein constitutes legal advice, nor should it be relied upon or interpreted as such. This communication is for general informational purposes only and is not a substitute for legal counsel. Readers should not act or refrain from acting based on any information provided without seeking appropriate legal advice specific to their situation. For more information, visit www.buchalter.com.
