Brown v. Siwanoy Country Club

Background

Ann Pearlina Brown brought a proposed collective and class action under the Fair Labor Standards Act and the New York Labor Law. She alleged that Siwanoy Country Club failed to pay its golf caddies minimum wages, overtime wages, and New York spread-of-hours pay. She also alleged that the Club failed to provide required pay-rate notices and wage statements and failed to maintain sufficient employment records.

Brown alleged that she worked as a golf caddy during the 2020 golf season. According to the second amended complaint, caddies typically worked 40 to 54 hours per week, while Brown alleged that she typically worked 57 hours per week. The Club did not pay caddies directly. Instead, caddies received bag fees paid by golfers and discretionary tips. Brown alleged that the Club treated caddies as independent contractors and that there was no agreement allowing the bag fees to count toward the Club’s minimum-wage and overtime obligations.

The Club moved to dismiss under Federal Rule of Civil Procedure 12(b)(1), which concerns subject-matter jurisdiction, and Rule 12(b)(6), which concerns whether a complaint states a legally sufficient claim. The Club argued that Brown’s Fair Labor Standards Act claims were barred by the statute of limitations because she had not plausibly alleged a willful violation. It also argued that her allegations did not support claims for unpaid wages.

Court’s reasoning

The Fair Labor Standards Act generally has a two-year limitations period, which can extend to three years for a willful violation. A willful violation requires facts suggesting that the employer knew its conduct was prohibited or recklessly disregarded that possibility. The court had dismissed Brown’s earlier complaint without prejudice because it lacked sufficient factual allegations supporting willfulness.

The court found that several of Brown’s new allegations were insufficient by themselves. The Club’s long operating history did not alone show that it knew its caddy-compensation practices were unlawful. Allegations that the Club failed to check whether it was complying with wage laws merely repeated the legal standard. Brown also did not provide enough detail about the Club’s other employees or comparable golf clubs to support some of her theories, and her allegation that caddies feared retaliation was speculative.

The court nevertheless held that Brown’s allegation that numerous caddies complained to the Caddy Master about receiving no pay for time spent at the Club without a golf assignment was enough to make willfulness plausible at the pleading stage. The Club allegedly did not change its compensation practices or otherwise respond to those complaints. Although the court described the allegations as thin, it emphasized that Brown needed to show plausibility, not prove that willfulness was probable or certain.

Because the court denied the motion, it retained jurisdiction over Brown’s state-law claims. The opinion did not decide whether the Club actually violated the Fair Labor Standards Act or New York Labor Law, whether Brown is entitled to damages, or whether a collective or class action will ultimately be certified.

Disposition

Judge Román denied Siwanoy Country Club’s motion to dismiss. The Club was directed to file an answer by October 21, 2025, and the parties were directed to confer and submit a case-management plan and scheduling order by November 4, 2025. The case therefore remained pending after this order.