This happened to me with the very 1st oil change. I bitched so hard the stealership sent the shop foreman out to my house to look at it. Granted it was only 6 miles for him, but I told them that I refuse to drive it back to them.
Oil pan drain bolt was tight, filter was on tight, oil level was correct. Simple fact, lazy tech who doesn't care & didn't do his job. Stealership gave me a complimentary oil change & tire rotation.
When I went in for the comp oil change I told the service advisor to be sure to have the tech wipe up his mess or I would be getting another complimentary oil change & tire rotation & I would take my bitching to a higher level & I would go to a different shop.
Edit: the comp oil change was done and no drops of oil on my garage floor... I would do my own oil change but I physically am unable.