Lubinski v. Johnson Controls, Inc.

Background

David Lubinski, Ryan R. Kenny, Michael A. Cornale, Anthony Santiago, Diego D. Dias, and Sean Morelli sued Johnson Controls, Inc., individually and on behalf of other similarly situated people. The opinion states that the plaintiffs are steamfitters and plumbers for Johnson Controls and asserted several federal and state wage-and-hour claims.

The order concerns two claims under New York Labor Law. The Third Cause of Action alleged that Johnson Controls failed to provide an accurate wage statement with every wage payment. The Fourth Cause of Action alleged that Johnson Controls failed to provide notices stating the plaintiffs’ pay rates and paydays.

Motion and Legal Standard

Johnson Controls filed a partial motion to dismiss those two causes of action under Federal Rule of Civil Procedure 12(b)(1), arguing that the plaintiffs lacked subject-matter jurisdiction because they lacked standing under Article III of the Constitution. Article III standing requires a plaintiff to allege an injury in fact, a connection between that injury and the challenged conduct, and a likelihood that a favorable decision would remedy the injury.

Because Johnson Controls presented a facial challenge based on the complaint and its attachments, the court accepted the complaint’s material factual allegations as true and drew reasonable inferences in the plaintiffs’ favor. The court also applied the rule that a statutory violation alone does not establish standing unless the plaintiff suffered concrete harm.

Ruling

The court held that the plaintiffs pleaded an injury in fact sufficient to establish Article III standing. The plaintiffs alleged that Johnson Controls’ failure to provide the required wage statements and notices denied them information needed to determine whether they were paid according to applicable prevailing wage rates on public job sites, received required overtime premiums, and received the supplemental benefits to which they were entitled.

The court noted that it had previously held that similar allegations were sufficient to establish standing under the Supreme Court’s decision in TransUnion LLC v. Ramirez. It therefore denied Johnson Controls’ partial motion to dismiss. The order did not decide whether Johnson Controls actually violated the wage laws; it resolved only the standing challenge to these two claims. Johnson Controls was ordered to file its answer to the amended complaint by July 30, 2024.