by Michael Fox
Following its decision last month in Martinez-Mendoza v. Champion International Corp., (11th Cir. Aug. 5, 2003) [pdf], the Court upheld a district court's determination that employees of a Farm Labor Contractor were not jointly employed by the company which had hired them to plant seedlings on its forest lands. Gonzalez-Sanchez v. International Paper (11th Cir. 9/25/03) [pdf]. Running through the 7 factors it identified in Champion, the Court found while there might be slight differences, they were not enough to make International Paper a joint employer.