A federal court in Nevada granted a motion to dismiss employment-related claims brought by a franchisee’s former employee against the franchisor because the employee failed to sufficiently plead the franchisor was a joint employer. Paige v. ARCNV, Inc., 2026 WL 2475915 (D. Nev. Aug. 24, 2026). Angeletta Paige, a former salon leader at a Regis Corporation-franchised salon owned by ARCNV, Inc., brought suit in the district court in Nevada, alleging that ARCNV and Regis underreported and underpaid her wages in violation of the Fair Labor Standards Act and related state law. Paige also pleaded discrimination, retaliation, hostile work environment, and constructive discharge claims. Paige alleged she was paid through product and service commissions and tips, but failed to receive wages for mandatory salon events, Zoom calls, and other meetings. Paige also alleged various discrimination claims based on a claimed collective campaign by her white managers to constructively discharge her as the sole Black stylist at the salon. Both ARCNV and Regis moved to dismiss the claims arguing that Paige was exempt from overtime as a matter of law and that she failed to adequately plead her claims. Regis further alleged that Paige failed to obtain consent or leave to file her amended complaint and failed to allege sufficient facts to establish that Regis was a joint employer. The district court granted ARCNV’s motion in part on certain wage claims and dismissed all claims against Regis.
The core issue related to Regis was whether Paige alleged sufficient facts to support her contention that she was jointly employed by ARCNV and Regis. The court found that the paystubs Paige attached to her amended complaint contradicted her joint-employer claims because, while Paige alleged Regis operated the salon at which she worked, the paystubs indicated she was paid by ARCNV, not Regis. The court also declined to consider the team member manual and franchise agreement that Paige attached to her opposition to Regis’ motion to dismiss after she declined to attach them to her amended complaint. Further, the court concluded that that Paige’s joint references to “defendants” in her allegations were insufficient to establish the specific retaliatory actions taken by Regis based on the specific, conflicting allegations that ARCNV demoted and constructively fired Paige.