Detroit landlord and real estate investor Dennis Kefallinos has been hit with a federal lawsuit because he didn't pay at least two dancers at Bouzouki, the strip club he owns in the city's Greektown neighborhood.

It's the latest Fair Labor Standards Act complaint filed against a local club owner, coming roughly around the same time that Alan Markovitz, who owns The Flight Club in Inkster and The Coliseum and Penthouse Club strip clubs on Eight Mile Road in Detroit, was targeted with a similar lawsuit by two former dancers and a DJ from the suburban Wayne County club.

The class action complaint filed in June by two former Bouzouki dancers comes amid a wave of settlements nationally in which clubs have paid millions in back-due wages, in general because they were classifying dancers and other workers such as bouncers and DJs as independent contractors rather than employees, allowing them to skirt federal wage laws. Cases have been brought virtually all over the country, from Las Vegas to Denver, Pittsburgh to Dallas.

The University of Illinois College of Law's Michael LeRoy, in "Bare Minimum: Stripping Pay for Independent Contractors in the Share Economy" published in 2017 in the William & Mary Journal of Race, Gender, and Social Justice, writes that of 75 federal and state court labor rulings he found, 38 determined that dancers were employees while only three found that they are independent contractors. (The other 34 were decided not on employment status, but on a procedural ruling, he wrote.)

"When there is a challenge waged, it's very rare that it doesn't prevail," said Megan Bonanni, equity partner for Royal Oak-based law firm Pitt McGehee Palmer & Rivers PC. She represents the plaintiffs in the Markovitz cases and successfully sued strip club chain Déjà Vu, netting $6.5 million for more than 28,000 workers in a case that wrapped earlier this year when the U.S. Sixth Court of Appeals upheld a May 2017 decision.

Bonanni said even though she has been victorious in earlier cases against the club owner, not much has changed.

"I asked at the time, I had made the request that they create an education program, do a change-over, converting dancers from independent contractors to employees, and I told their attorney that's what I thought was the right thing to do, and also that I'd be back if you don't correct these illegal employment practices," Bonanni said. "That's why we are back."

It's more complicated than just a demand for an hourly wage and overtime pay, health benefits and worker's compensation, some argue.

In California, a state Supreme Court ruling is making it more difficult for dancers to be considered independent contractors, which sparked concern from Stormy Daniels, who wrote in a February op-ed in the Los Angeles Times that work status allowed for more flexible hours, the ability to move to clubs where the pay is better and increased ability to shield their identity. Daniels, the adult film star and exotic dancer who says she had an affair with President Donald Trump and was paid hush money, is also a spokeswoman for Déjà Vu.

"In this industry, classification (as employee or independent contractor) is sometimes a very fact-specific inquiry and there is not one size fits all," said Christopher Trebilcock, member for Detroit-based law firm Clark Hill PLC specializing in labor and employment law. "There is not one size fits all for clubs, or for entertainers. There may be entertainers who dance at multiple clubs, as well as private gigs. There are some that have established themselves as LLCs and run a business by dancing. There are others that work solely for one club."

Still, he said, independent contracting can work.

"There are lawful ways to compensate where entertainers are not employees," Trebilcock said. "You could set it up in ways where dancers establish their own schedule, come and go when they want. They keep all their own money, set their own prices for dances. If they have formed an LLC, that's always helpful."