Scott v. Cintas Corporation

Background

Isaiah Scott, a former Management Trainee at Cintas Corporation, filed a Third Amended Complaint alleging seven claims. He alleged that he worked approximately nine to ten hours or more per day and 45 to 55 hours or more per week from approximately October 2020 through approximately January 2022. He alleged that Cintas classified him as exempt from overtime, paid him an annual salary of approximately $65,000, and did not pay overtime wages.

Scott also alleged that he regularly did not receive required meal and rest periods. He specifically alleged that he did not receive an uninterrupted 30-minute meal period or two uninterrupted 10-minute rest periods during the week of December 7, 2020. He further alleged that Cintas failed to provide accurate wage statements and failed to pay all wages owed when he quit in January 2022.

Cintas moved under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not adequately state a legal claim. The court had previously dismissed Scott’s Second Amended Complaint but allowed him to amend it.

Claims and analysis

Scott’s first two claims sought unpaid overtime under the Fair Labor Standards Act and California law. The court held that he met the pleading requirement because he identified a specific workweek in which he allegedly worked approximately 55 hours, received no overtime pay, and had been classified as exempt. The court also found that his allegations that supervisors assigned and closely supervised his work plausibly showed that Cintas knew or should have known about the overtime.

The court allowed Scott’s meal-break claim to proceed. Scott alleged that Cintas did not have a policy or practice of providing meal periods to Management Trainees, failed to schedule those periods, and required trainees to cover for other workers during their breaks. The court held that these allegations, including the alleged denial of a 30-minute uninterrupted meal period on December 7, 2020, were sufficient at the motion-to-dismiss stage. The court also rejected Cintas’s argument that Scott had waived his meal periods because waiver is an affirmative defense that Cintas would have to establish, and Cintas had not presented admissible evidence resolving that issue as a matter of law.

The court also allowed Scott’s rest-break claim to proceed. Scott alleged that Cintas had no policy or practice of providing rest periods to Management Trainees and that he did not receive the required uninterrupted breaks. The court explained that an employer must authorize and permit required rest breaks; if a break was never authorized, an employee’s alleged waiver does not defeat the claim at this stage.

The court allowed Scott’s wage-statement claim to proceed. Scott alleged that Cintas’s statements did not accurately show his gross wages, total hours, net wages, applicable hourly rates, or hours worked at each rate. The court found it plausible that Cintas failed to record his overtime hours because it had classified him as exempt. It also found that Scott adequately alleged injury and that the violations were knowing and intentional.

The court allowed Scott’s claim for failure to pay all wages upon termination to proceed because that claim was based on the underlying wage violations, which the court had found adequately pleaded.

Scott’s seventh claim was under California’s Unfair Competition Law, which prohibits unlawful, unfair, or fraudulent business practices and generally provides equitable remedies. Scott based this claim on the alleged wage-law violations. The court held that he had viable legal claims for damages based on the same conduct and had not alleged why money damages would be inadequate. The court rejected Scott’s argument that the Unfair Competition Law’s longer limitations period alone made his other remedies inadequate.

Disposition

The court DENIED Cintas’s motion to dismiss as to all claims except Scott’s Unfair Competition Law claim. The court DISMISSED Scott’s Unfair Competition Law claim without prejudice and WITHOUT LEAVE TO AMEND. The order states that the claim may be refilled in state court, but it does not otherwise resolve the remaining claims or determine whether Cintas is ultimately liable.