Vogt v. Greenmarine Holding, LLC
This action was brought under the Worker Adjustment and Retraining Notification (WARN) Act by former employees of Outboard Marine Corporation (OMC), a bankrupt company, against several investment companies that owned or controlled OMC's stock. Plaintiffs alleged failure to provide a sixty-day notice before mass layoffs or plant closings. Defendants filed motions to dismiss for failure to state a claim. The court applied the Department of Labor's five-factor test for intercorporate WARN Act liability, particularly emphasizing de facto control over the mass layoff decision. The motions to dismiss were denied for Greenmarine Holdings, LLC, Quantum Industrial Partners, LDC, and Quantum Industrial Holdings, Ltd., due to sufficient allegations of de facto control, common ownership, and shared directors. However, the motions were granted for other defendants lacking such specific allegations.