A federal court in Maryland recently dismissed a former franchisee employee’s joint-employer-based claims against the franchisor and discrimination and retaliation claims against her franchisee employers. Sharp v. Arthur Murray Int’l Inc., 2025 WL 2938368 (D. Md. Oct. 16, 2025).
Mykia Sharp, a dance trainer at two franchised Arthur Murray Dance Studios, sued the franchisees and the franchisor, Arthur Murray International Inc., alleging racial and disability discrimination, a hostile work environment, retaliation, and wrongful termination. Among other things, Sharp alleged that after complaining to the studio manager at one franchised location about repetitive racially discriminatory comments and slurs, she was fired. Sharp stated that she was subsequently transferred to another franchised studio in Baltimore after her firing and later dismissed from that studio after filing a workers compensation claim. Arthur Murray and the franchisees all moved to dismiss Sharp’s claims.
The court granted Arthur Murray’s motion to dismiss, rejecting as insufficient Sharp’s “bare ‘labels and conclusions’” concerning Arthur Murray. Sharp’s complaint failed to allege facts from which it could be inferred that Arthur Murray jointly employed her, including, for instance, allegations that Arthur Murray was involved in her hiring or training, was aware of her workers’ compensation claim and instructed an employment decision as a result of that knowledge, was in possession of her employment records, or otherwise exerted sufficient control over the franchisees to constitute a joint employer. Instead, the complaint simply alleged that “at all relevant times, [Arthur Murray] employed the Plaintiff.” The court also granted the franchisees’ dispositive motions on Sharp’s discrimination and retaliation claims because Sharp failed to adequately plead or otherwise establish that the franchisees qualified as “employers” under relevant law by having fifteen or more employees.
*Asad Imam is a Law Clerk for Lathrop GPM who contributed to the writing of this post.