Hatcher v. Augustus
The plaintiff, Philip Hatcher, a 7-Eleven store manager, initiated an action under Title VII of the Civil Rights Act against the franchisee, Warner Augustus, and the franchisor, Southland Corporation. Hatcher alleged wrongful termination based on his religion after being fired for refusing to work on Sunday mornings. Southland Corporation moved for summary judgment, arguing it was not Hatcher's employer within the context of Title VII. The court applied a 'hybrid test,' which combines economic realities and common law agency tests, to determine employer status. Despite Southland providing payroll services to the franchisee, the court found that Augustus had exclusive control over Hatcher's employment. The court concluded that Southland was not Hatcher's 'employer' under Title VII and granted Southland's motion for summary judgment, dismissing the complaint against it.