A Superior Court judge has rejected a motion for summary judgment brought by Lighthouse Life Science Partners LLC that argued the plaintiff-employee was precluded as a matter of law from bringing Wage Act claims because the employee was also a minority member of the LLC.

Massachusetts Superior Court

SUMMARY: (court decision – opens in PDF)

Where a defendant limited liability company has moved for summary judgment under the Wage Act, that motion should be denied despite the defendant’s contention that the plaintiff is not an employee covered by the statute because he is a minority shareholder of the LLC.

“… There is nothing in the record showing that [plaintiff James] Raleigh had any authority over the daily operations of [defendant] Lighthouse [Life Science Partners, LLC]. Instead, Raleigh has produced evidence that he served Lighthouse in a sales capacity under the 2018 [Independent Sales Agent (ISA)] Agreement, was supervised by [defendant Douglas] Manchester and others at Lighthouse, and did not participate in the financial management of Lighthouse in any significant way. Under these circumstances, Defendants have failed to demonstrate a lack of any material dispute concerning whether Raleigh should be treated as an ‘employer’ who is precluded from claiming protections under the Wage Act. …”