A group of former workers has accused their previous employer of failing to pay required overtime wages, raising questions about worker classification and wage practices under federal law. The complaint was filed by Kyler Deculus, Landon Gartman, and Riley Martin in the United States District Court for the Western District of Louisiana on April 1, 2026, naming Dauntless Services, LLC along with Ashley Fritz and Chad Fritz as defendants.
According to the filing, the plaintiffs allege that while employed as Cart Delivery & Removal Technicians for Dauntless Services, they routinely worked more than 40 hours per week but were not compensated at an overtime rate. Instead, they report being paid a daily rate regardless of total hours worked. The lawsuit states that these actions violate the Fair Labor Standards Act (FLSA), which requires non-exempt employees to receive overtime pay at one and one-half times their regular rate for hours exceeding 40 in a workweek.
The complaint outlines that Dauntless Services is described by its owners as “a small, family-owned LLC that partners with major waste management companies to handle the delivery and removal of trash carts.” Plaintiffs state that their job involved traveling across the United States to deliver and remove trash carts for both residential and commercial customers. They argue that although classified by Dauntless as “independent contractors,” the economic reality of their relationship made them employees under federal law. According to the document: “Plaintiffs had no opportunity for profit or loss independent of Defendants, did not operate independent businesses, and did not make significant capital investments in equipment or materials required to perform their jobs.”
The filing further claims that defendants Ashley Fritz (a member) and Chad Fritz (the manager) exercised operational control over key aspects of Dauntless’s business including hiring decisions, scheduling, directing work activities, setting pay policies, supervising employees, enforcing company policies, controlling payroll practices, and making financial decisions related to wage payments. The plaintiffs allege that both individuals are therefore jointly responsible with Dauntless Services for any damages owed.
Plaintiffs assert they were integral to the business operations of Dauntless Services and worked continuously over an extended period in a manner consistent with employee status rather than independent contractor status. They state: “Defendants controlled the manner, means, schedule, locations, and conditions of Plaintiffs’ work,” adding that they used company-owned trucks and trailers for nationwide travel.
The complaint details how plaintiffs regularly handled goods such as vehicles and equipment manufactured outside Louisiana—further supporting coverage under FLSA provisions regarding interstate commerce. It also alleges that during each relevant year Dauntless had annual gross sales or business exceeding $500,000.
In terms of specific legal violations cited in the suit: “Despite the fact that Plaintiffs regularly and routinely worked in excess of 40 hours during each workweek,” it is alleged they “were never paid overtime compensation.” Plaintiffs claim some weeks involved working more than 80 hours when including travel time.
As remedies from the court, plaintiffs seek recovery for unpaid overtime wages pursuant to FLSA section 216(b), an equal amount as liquidated damages due to what they describe as knowing or willful violations by defendants (“Defendants knowingly and willfully violated the FLSA”), reasonable attorney’s fees and costs associated with bringing this action—including pre-judgment and post-judgment interest—and any equitable relief deemed appropriate by the court.
The attorneys representing Kyler Deculus, Landon Gartman, and Riley Martin are Brian F. Blackwell (Bar No. 18119) and William J. Wilson (Bar No. 36732) from Blackwell & Bullman LLC based in Baton Rouge. The case is identified as Civil Action No. 29-1029.
Source: 626cv01029_Kyler_Deculus_v_Dauntless_Services_Complaint_Western_District_of_Louisiana.pdf
