Braaten v. Slipstream Group

Background

Erin Braaten was hired by Slipstream Group, Inc. as its Chief People Officer — a senior human-resources role — on October 8, 2024, at an annual salary of $155,000 paid semi-monthly. She began work on October 28, 2024, and received her first paycheck on November 7, 2024. She believed the paycheck was lower than it should have been and suspected the shortfall was due to improper salary proration.

Braaten reported the issue to Slipstream's CEO, who directed her to investigate with the company's finance and payroll teams. Through that investigation, she formed the belief that Slipstream's proration practices violated the Fair Labor Standards Act (FLSA) — a federal law governing minimum wage, overtime, and pay recordkeeping — and related state laws. She escalated her concerns to Slipstream's Chief Financial Officer, Controller, and General Counsel Tim Mathison.

Mathison, working with outside counsel, conducted a risk assessment and concluded that Slipstream's pay practices complied with federal and state law. Braaten disagreed, relying on her industry experience, and continued to press her concerns. She also alleged that Slipstream failed to provide her with a wage statement notice or earnings statement as required by law. Slipstream investigated, again found its practices lawful, and on December 9, 2024 — roughly six weeks after Braaten started — terminated her employment, citing her "confrontational manner."

Braaten filed suit in Ramsey County District Court on May 2, 2025. Slipstream removed the case to federal court. Braaten's complaint asserts: (1) retaliation in violation of the Minnesota Whistleblower Act; (2) retaliation in violation of the Minnesota Payment of Wages Act; (3) breach of employment contract; and (4) failure to pay wages in violation of the Minnesota Payment of Wages Act.

Motion at Issue

Slipstream filed a motion for judgment on the pleadings under Federal Rule of Civil Procedure 12(c). A Rule 12(c) motion allows a party to seek dismissal based solely on the allegations in the complaint and the defendant's answer, before any discovery occurs. The legal standard for Rule 12(c) is the same as for a Rule 12(b)(6) motion to dismiss: the complaint must contain sufficient factual matter, accepted as true, to state a claim that is plausible on its face.

Court's Analysis

The court noted that the parties appeared to agree the viability of all of Braaten's claims hinges largely on whether Slipstream's pay practices actually complied with the law. However, Judge Doty declined to resolve that factual and legal question on the pleadings alone.

Applying the plausibility standard from Ashcroft v. Iqbal and Bell Atlantic Corp. v. Twombly — which requires more than speculation but does not demand detailed proof at the pleading stage — the court found that Braaten had alleged enough to allow her claims to proceed. The court was candid that it "suspects that Braaten's claims may not ultimately be viable," but stated it "simply cannot make that determination without a proper factual record."

Disposition

The court denied Slipstream's motion for judgment on the pleadings. The case will proceed to further litigation. The opinion does not address discovery schedules or any next steps.

Notes on Scope

The court did not rule on the merits of any of Braaten's claims. It ruled only that her allegations, taken as true at this stage, are sufficient to allow the case to continue. The court expressly flagged doubt about the ultimate viability of her claims, which is notable given the plausibility standard is generally considered a relatively low threshold.