A group of Michigan phlebotomists are a mobile blood collection company’s employees, not independent contractors, so federal law entitles them to overtime pay, a judge said.
The workers put forth evidence that the economic reality of their relationship with Mobile Phlebotomy of Central Michigan LLC makes them employees protected under the Fair Labor Standards Act, the US District Court for the Eastern District of Michigan said Monday, granting their motion for summary judgment.
MPCM contracts with phlebotomists to serve hospitals and other health-care providers in Central Michigan. The workers—whose agreements with the company identify them as independent contractors—alleged MPCM misclassified them and failed to adequately pay for their extra hours.
The economic reality test looks at six factors to determine whether workers are employees or contractors. Five of those factors support an employment relationship here, Judge Thomas L. Ludington said.
The workers had a relatively permanent relationship with MPCM, and they didn’t have to invest in job equipment, Ludington said. The phlebotomists didn’t have control over profits, while MPCM did have control over how they performed their work, which was integral to its business, the judge added.
The company argued that the workers originally agreed they were contractors. But the US Court of Appeals for the Sixth Circuit “already rejected contractual terms designating the relationship as an independent contractor as a dispositive factor,” Ludington said.
The workers also moved to block MPCM from introducing certain evidence. Ludington denied that motion as moot because he granted the summary judgment bid and the only thing left for the court to address is how much overtime pay the company owes the phlebotomists.
Blanchard & Walker PLLC represents the workers. Smith Bovill PC represents MPCM.
The case is Rayford v. Mobile Phlebotomy of Cent. Mich. LLC, 2025 BL 464768, E.D. Mich., No. 1:23-cv-13012, 12/29/25.
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