In Garcia-Celestino v. Ruiz Harvesting, Inc., the Eleventh Circuit distinguished the joint employer standard under the Fair Labor Standards Act (FLSA) and common law. Each standard turns on the applicable definition of “employee” and “control,” but are not the same. There, migrant workers under the H-2A visa program filed suit against their employer and a citrus grove owner for minimum wage violations under the FLSA and for breach of their contract, which was based on federal immigration statutes and regulations. The court looked at whether or not the citrus grove owner was a joint employer.