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 New York Labor Law. They alleged that they worked as golf caddies at the Club and that the Club failed to pay them minimum and overtime wages.

According to the allegations, the Club did not pay caddies an hourly rate, salary, piece rate, or other compensation. Instead, golfers paid caddies a Club-determined $60 fee for each golf bag carried during a round, and caddies could also receive tips. The caddies allegedly were required to remain at the Club while waiting to be assigned to golfers, but received no compensation for that waiting time. The complaint also alleged that caddies complained about being present without pay and that the Caddy Master threatened not to assign complaining caddies to golfers.

Motion to Dismiss

The Club moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not plausibly state a claim for relief. The Club argued that the FLSA claims were untimely because the plaintiffs had not plausibly alleged that any violation was willful. The FLSA generally provides a two-year limitations period, extended to three years for willful violations. The Club also argued that, if the federal claims were dismissed, the court should decline to exercise supplemental jurisdiction over the New York claims.

The court explained that, at the motion-to-dismiss stage, it had to treat well-pleaded factual allegations as true and draw reasonable inferences in the plaintiffs’ favor. Lewis and Williams were not alleged to have worked at the Club after 2020, while the action was filed on July 27, 2023. Their FLSA claims therefore depended on the alleged violations being willful so that the three-year period could apply.

Court’s Analysis

The court rejected the plaintiffs’ allegations that the Club’s long operation since 1921, by itself, plausibly showed willfulness. The court also found insufficient the allegation that the Club knew it was violating wage laws because it believed caddies would not take legal action.

The court nevertheless found the allegations about repeated employee complaints sufficient, although only barely, to plausibly allege willfulness. It reasoned that complaints about being required to remain at the Club without pay could have put the Club on notice that its practices violated minimum-wage requirements. The alleged threats by the Caddy Master in response to those complaints further supported a plausible inference that the Club knew about the challenged practices and deliberately disregarded the risk that they violated the FLSA.

Ruling and Disposition

Judge Kenneth M. Karas concluded that the plaintiffs had plausibly alleged a willful FLSA violation and that the three-year limitations period applied to the federal allegations. The court denied the Club’s motion to dismiss. Because the federal claims remained, the court retained supplemental jurisdiction over the plaintiffs’ New York Labor Law claims. The Clerk was directed to close the pending motion, and the court scheduled a status conference for October 28, 2025.