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Onyeanusi v. Times-Picayune Pub. Corp.

Citations: 485 So. 2d 622; 55 Fair Empl. Prac. Cas. (BNA) 521Docket: CA-4328

Court: Louisiana Court of Appeal; March 11, 1986; Louisiana; State Appellate Court

Narrative Opinion Summary

The case revolves around an employment discrimination lawsuit filed by Onyeanusi against Times-Picayune Publishing Company under La.R.S. 23:1006. Onyeanusi alleged that he faced intentional discrimination by the company, which he claimed to be his employer. The District Court granted summary judgment in favor of Times-Picayune, and Onyeanusi appealed. Central to the case was the determination of whether Onyeanusi was an employee or an independent contractor under the statutory definition of 'employer' requiring compensation and a workforce exceeding 15 employees. The contract characterized Onyeanusi as an independent contractor, purchasing newspapers for resale and maintaining profits without being listed on the company's payroll or receiving typical employee benefits. Despite asserting that the 'right-of-control' test should establish his employee status, the court upheld the statutory definition as decisive. The court found no evidence of an employer-employee relationship, affirming the trial court's decision and dismissing the appeal at Onyeanusi's expense. The ruling underscores the importance of adhering to statutory definitions in employment discrimination claims.

Legal Issues Addressed

Definition of Employer under La.R.S. 23:1006

Application: The court applied the statutory definition of 'employer,' requiring compensation for services and more than 15 employees, to determine that Times-Picayune was not Onyeanusi's employer.

Reasoning: La.R.S. 23:1006 defines an 'employer' as a person who compensates an individual for services rendered and employs more than 15 employees.

Independent Contractor Status

Application: The court found that Onyeanusi was classified as an independent contractor because he purchased newspapers for resale and did not receive compensation from Times-Picayune.

Reasoning: The contract between Onyeanusi and Times-Picayune classified him as an independent contractor responsible for purchasing newspapers for resale and delivery.

Intentional Employment Discrimination under La.R.S. 23:1006

Application: The court analyzed whether Onyeanusi could establish a claim of employment discrimination against Times-Picayune under the Louisiana statute based on his purported status as an employee.

Reasoning: Ume Onyeanusi, a black male, filed a suit against Times-Picayune Publishing Company alleging intentional employment discrimination under La.R.S. 23:1006.

Right-of-Control Test in Employment Relationships

Application: The court rejected Onyeanusi's argument that the right-of-control test should determine his employment status, holding that the statutory definition was controlling.

Reasoning: The court rejected Onyeanusi's argument regarding the 'right-of-control' test for employer-employee relationships, emphasizing that the specific statutory definition of 'employer' under La.R.S. 23:1006 was controlling.

Summary Judgment in Employment Discrimination Claims

Application: The court affirmed the grant of summary judgment for Times-Picayune, finding no genuine issue of material fact regarding Onyeanusi's employment status.

Reasoning: The court concluded that the record presented no genuine issue of material fact regarding the employer status of Times-Picayune and affirmed the trial court's granting of summary judgment.