Employment – Single integrated enterprise – Joint employer

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Where one of two defendants in a discrimination suit has filed a motion to dismiss arguing that it was not the plaintiff’s employer, that motion should be denied because the plaintiff has plausibly alleged that the two defendants operated as a single integrated enterprise.

“Plaintiff Sandra Miller brings employment discrimination claims against defendants Siemens Medical Solutions USA, Inc. (‘Siemens Medical’) and Siemens Healthcare Diagnostics, Inc. (‘Siemens Healthcare’). She alleges that the defendants discriminated against her on the basis of age and disability and that they unlawfully terminated her in retaliation for requesting a reasonable accommodation and for reporting discriminatory acts, in violation of federal and state law. Siemens Medical has moved to dismiss all claims against it, arguing that it cannot be held liable for her claims because it is neither a single integrated enterprise nor a joint employer with Siemens Healthcare. Because Miller has plausibly alleged that Siemens Medical and Siemens Healthcare operated as a single integrated enterprise, the motion will be denied. …

“Siemens Medical contends that Miller’s claims against it must be dismissed because she has not plausibly alleged that it was her employer or that it jointly employed her along with Siemens Healthcare. …

“… To determine if two or more companies should count as a single integrated employer, courts consider four factors: ‘(i) “centralized control over labor relations”; (ii) “interrelation between operations”; (iii) “common management”; and (iv) “common ownership.”’ …

“… Miller has plausibly alleged that Siemens Medical, the parent company of Siemens Healthcare, exercised some control over decisions related to her employment. …

“… Miller has plausibly alleged some interrelation between the operations of Siemens Medical and Siemens Healthcare. The two entities operated out of the same business location in East Walpole, Massachusetts. … The companies also share at least one corporate officer and director: Caroline Elaine Ochital, who is an Assistant Secretary for both Siemens Healthcare and Siemens Medical. … This commonality in corporate leadership supports both the allegation of an interrelation between the operations of Siemens Medical and Siemens Healthcare, and the allegation that the two entities shared some common management. …

“… Here, Siemens Healthcare is a wholly owned subsidiary of Siemens Medical, and both defendants are subsidiaries of Siemens Healthineers [Organization]. … Miller has, therefore, plausibly alleged common ownership.

“The allegations in Miller’s complaint, construed in the light most favorable to her, give rise to the plausible inference that Siemens Medical and Siemens Healthcare were a single integrated employer, such that Miller may seek to hold Siemens Medical responsible for her employment discrimination claims. Although Miller would need to introduce more robust evidence of the interrelationship between the two entities to prevail on her single integrated employer theory, the allegations in her complaint are sufficient, at this stage, to survive Siemens Medical’s motion to dismiss. And because Miller has plausibly alleged that the defendants are a single integrated employer, the Court need not address her alternative theory that she was jointly employed by the defendants. …”

Miller v. Siemens Medical Solutions USA, Inc., et al. (Lawyers Weekly No. 02-502-25) (8 pages) (Kobick, J.) (Docket No. 1:24-cv-12854-JEK) (Sept. 11, 2025).

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