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In our previous post, we addressed the National Labor Relations Board’s finding that franchisors can be considered joint employers of its franchisee’s employees. The issue of the joint employer relationship continues to be a hot button issue. Just last week, the Missouri Supreme Court announced a new rule of joint employer liability under the Missouri Minimum Wage Law (MMWL). In Tolentino v. Starwood Hotels & Resorts Worldwide, Inc., No. SC93379 (Mo. banc Aug. 19, 2014), the court took a broad view of joint employers – even when criminal activity is involved.