Parker v. Battle Creek Pizza, Inc., No. 22-2119 (6th Cir. 2024)
Annotate this Case
In this consolidated appeal involving two cases from the Western District of Michigan and the Southern District of Ohio, the United States Court of Appeals for the Sixth Circuit ruled on how pizza-delivery drivers should be reimbursed for the cost of using their vehicles for work. The main dispute lay in the reimbursement method: the Michigan court sided with the drivers, stating they should be reimbursed based on a mileage rate published by the IRS, while the Ohio court agreed with the employers, stating a "reasonable approximation" of the drivers' costs suffices. The Sixth Circuit disagreed with both courts and vacated their decisions.
The central issue involved the Fair Labor Standards Act (FLSA) requirement that employers pay each employee at least a minimum wage. The court found that if an employer required a minimum-wage employee to provide his own "tools" for work (in this case, their own vehicles), the employer must reimburse them for 100% of the cost of doing so. The court emphasized that the FLSA mandates that each employee be paid at least the specified minimum wage, not a "reasonable approximation".
The court also disagreed with the plaintiffs’ argument that they should be reimbursed using the IRS's standard-mileage rate for business deductions, as it is a nationwide average and does not consider the individual costs of each driver. The court emphasized that the statute entitles a minimum-wage employee to reimbursement of actual costs incurred on the employer's behalf, neither more nor less. The case was remanded back to the lower courts for further proceedings.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.