Payroll company not joint employer of crew member employed by tv production company

The latest issue of Proskauer's California Employment Law Notes notes that in Futrell v. Payday Cal., Inc., the California Court of Appeal has held that Reactor Films' payroll company, Payday California, was not a joint employer of crew members who worked for Reactor, a TV commercial production company. This meant that the payroll company was not liable to crew members who alleged they had not been paid required overtime.