In Ash v. Sambodromo, LLC, No. 09-20406, (S.D. Fla. 11/17/09), Lorna Ash, a former server and host at a Sushi Samba restaurant in Florida, sued the restaurant for violating the Fair Labor Standards Act. The restaurant moved for summary judgment on five grounds. In ruling against Sushi Samba on all but the retaliation issue, the court once again highlights why tip cases have become such an albatross for restaurant owners: They require a very fact-specific analysis.