Salas v. Laundry 210 LLC d/b/a Gracies Laundry

Background

Floridelia Salas moved for default judgment on September 9, 2025. A telephonic hearing on that motion was scheduled for October 23, 2025.

The complaint alleges that the defendants violated the Fair Labor Standards Act (FLSA), including by failing to comply with federal recordkeeping requirements under 29 U.S.C. § 211(c). The complaint also alleges that the defendants failed to pay Salas the federal and New York minimum wages. But the complaint states elsewhere that Salas was paid between $12.00 and $13.50 per hour, which the court noted exceeds the federal minimum wage of $7.25 per hour.

Court’s Concerns

The court noted that other courts in the Southern District of New York have held that the FLSA does not provide a private right of action for an employer’s recordkeeping violation. The court also noted that the FLSA does not create a federal cause of action for violations of New York State or New York City labor law.

The court therefore directed Salas to explain why the facts alleged in the complaint state a cause of action under federal law. The court also directed her to explain why it should exercise supplemental jurisdiction—authority to hear related state-law claims—in the event the complaint does not state a federal claim. The requested explanation must address whether the state-law wage claims arise from a common set of facts with the alleged FLSA recordkeeping violation and whether continuing with those claims would promote judicial economy, convenience, fairness, and respect for state courts.

Ruling and Effect

Judge John P. Cronan ordered Salas to file the requested letter by October 18, 2025. The order did not decide the default-judgment motion, enter default judgment, or dismiss any claim. The scheduled telephonic hearing remained set for October 23, 2025.