Lewis v. Pelham Country Club

Background

Kameika Lewis, Ann Pearlina Brown, Adrian Williams, and Myana Brown brought a proposed collective and class action against Pelham Country Club under the Fair Labor Standards Act (FLSA) and the New York Labor Law (NYLL). They alleged that they worked as golf caddies at the Club and were not paid directly by it. Instead, golfers paid a $60 fee for each golf bag carried, and sometimes gave additional tips. The plaintiffs alleged that these payments were their only compensation and that the Club failed to pay minimum and overtime wages.

Lewis and Williams asserted the FLSA claims. The complaint alleged that Lewis and Williams worked through the 2020 golf season, while the action was filed on July 27, 2023. The remaining claims arose under the NYLL and alleged unpaid overtime, unpaid minimum wages, unpaid spread-of-hours compensation, and failures to provide wage notices and accurate wage statements.

Motion to dismiss

Pelham Country Club moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not plausibly state a legal claim. Among other arguments, the Club contended that the FLSA claims were time-barred because the plaintiffs did not plausibly allege a willful violation. The Club also argued that the bag fees were wages and that the plaintiffs therefore received at least the federal minimum wage. The court did not reach those latter merits arguments after resolving the limitations issue.

The FLSA generally allows claims filed within two years of a violation, or within three years if the employer’s violation was willful. The court explained that willfulness requires facts supporting a plausible inference that the employer knew its conduct violated the FLSA or recklessly disregarded that risk. Merely alleging that a violation was “willful,” or asserting conclusions about the employer’s knowledge, intent, or recordkeeping, is not enough.

Court’s analysis

The court held that Lewis and Williams did not plausibly allege willfulness. Their allegations that the Club knew it had to pay minimum and overtime wages, structured its compensation policy to minimize labor costs, misclassified caddies as independent contractors, and knowingly avoided recordkeeping requirements were treated as conclusions rather than supporting facts. The court also stated that the alleged lack of time and loop records, without more, could at most suggest negligence, which does not establish willfulness under the FLSA.

Because Lewis and Williams worked through October 2020 and the action was filed more than two years later, the court applied the ordinary two-year limitations period and dismissed their FLSA claims as time-barred. The court expressly did not decide whether the caddies were employees or independent contractors, whether the bag fees counted as wages or tips, or whether the Club otherwise violated the FLSA.

After dismissing all federal claims, the court declined to exercise supplemental jurisdiction—the authority to hear related state-law claims—involving the NYLL. It therefore dismissed the plaintiffs’ NYLL claims without prejudice.

Disposition

Judge Kenneth M. Karas granted the Club’s motion to dismiss. The court dismissed the Amended Complaint without prejudice and allowed the plaintiffs 30 days to file a second amended complaint alleging additional facts and addressing the identified deficiencies. The court stated that, if the plaintiffs did not timely file that pleading, the dismissed claims may be dismissed with prejudice. The Clerk was directed to terminate the pending motion.